Data Processing Agreement (DPA)

This is a template DPA. Contact us for a signed copy tailored to your organisation.

1. Scope and Purpose

This Data Processing Agreement (“DPA”) forms part of the agreement between the Customer (“Controller”) and Sovrio (“Processor”) for the provision of QR code management and redirect services.

The Processor shall process personal data only on documented instructions from the Controller, including with regard to transfers of personal data to a third country or an international organisation, unless required to do so by Union or Member State law to which the Processor is subject.

2. Data Processed

The following categories of personal data may be processed depending on the privacy level configured by the Controller:

  • IP addresses (full or hashed, depending on privacy level)
  • Device and browser metadata
  • Geographic location (country level)
  • Timestamps of scan events
  • Language preferences

3. Purpose of Processing

Personal data is processed for the following purposes:

  • QR code redirect analytics and reporting
  • Performance monitoring and service reliability
  • Fraud prevention and abuse detection

4. Retention

Data is retained per the Controller's tenant configuration, with configurable retention periods between 7 and 365 days.

Automatic deletion occurs after the configured retention period expires. Manual deletion is also available at any time via the GDPR data deletion endpoint.

5. Subprocessors

The current list of subprocessors is maintained on our compliance page.

The Processor shall inform the Controller of any intended changes concerning the addition or replacement of subprocessors at least 30 days in advance, thereby giving the Controller the opportunity to object to such changes.

6. Data Subject Rights

The Processor shall assist the Controller in fulfilling its obligation to respond to data subject requests, including:

  • Right of access (Article 15)
  • Right to rectification (Article 16)
  • Right to erasure (Article 17)
  • Right to restriction of processing (Article 18)
  • Right to data portability (Article 20)
  • Right to object (Article 21)

7. Security Measures

The Processor implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk. All infrastructure is hosted on Hetzner (ISO 27001 certified, GDPR compliant) within the European Union. A full overview of security measures is available on our compliance page.

8. Breach Notification

The Processor shall notify the Controller without undue delay after becoming aware of a personal data breach, and in any event within 72 hours of discovery.

The notification shall include the nature of the breach, the categories and approximate number of data subjects concerned, the likely consequences, and the measures taken or proposed to address the breach.

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