Data processing agreement (AVV)

For Controllers established in Germany, Austria, Switzerland or Liechtenstein the German version is binding; for all others this English version is binding (§ 16(6)).

Parties

Controller: the natural or legal person who uses a Spoonbill account for their commercial or self-employed professional activity (the "Controller").

Processor: Dzmitry Kandratsenka, sole trader (empresário em nome individual), trading as "DK Labs", Rua Miguel Araujo 141, 4425-177 Porto, Portugal, tax number (NIF) 317 045 709 (the "Processor").

§ 1Subject matter and scope

(1) The Processor provides the Controller with the invoicing service Spoonbill (the "Service" or "Spoonbill"): the web app, the iPhone app and the interface both work through, under Spoonbill's Terms of Use. In doing so, it processes personal data that the Controller enters into Spoonbill, or receives through Spoonbill, about its clients and other persons, on behalf of the Controller (the "Contract Data").

(2) This agreement does not cover data for which the Processor is itself the controller: the Controller's account and sign-in data, the billing of the Spoonbill subscription, analysis of how the Service is used, advertising measurement, and messages to Spoonbill (feedback). Spoonbill's Privacy Policy governs those.

(3) This agreement applies to every account used for a commercial or self-employed professional activity. It supplements the Terms of Use.

§ 2Nature, purpose and scope of the processing

(1) Nature and purpose. The Processor processes Contract Data solely to provide the Service to the Controller. This includes:

1. storing, displaying, changing and deleting client data, including importing it from the phone's address book when the Controller triggers it;
2. creating quotes and invoices, including recurring ones, generating them as PDF files and, where the plan includes it, as electronic invoices (for example ZUGFeRD or XRechnung), and storing sent documents unchanged;
3. sending documents and the related messages by e-mail to the recipients the Controller names: invoices, quotes, acceptance confirmations, payment reminders and notices of expiring quotes, in each case at the Controller's request or according to its settings in Spoonbill;
4. providing, for each sent document, a client page under a personal link where the recipient can view and download the document, accept or decline a quote and, if the Controller has connected its own Stripe account, pay by card;
5. recording when a document was sent, first opened, accepted, declined or paid, and recording payments;
6. storing attachments and sending them with the document;
7. notifying the Controller on its phone if it has switched notifications on, for example that a client has accepted a quote;
8. receiving, reading, checking and storing electronic invoices that suppliers send to the Controller, once and to the extent the Controller uses this function;
9. exporting Contract Data and deleting it under § 12.

(2) Types of personal data.

1. client master data: name or company name, address, country, e-mail address, language, currency;
2. tax and invoicing details: VAT identification number, tax-exemption details, buyer reference (for example a Leitweg-ID), order number, payment term;
3. contents of quotes and invoices: line items, amounts, date and period of supply, notes and payment terms;
4. payment data: amount, date, payment method and reference; for card payments, the payment's identifier at Stripe;
5. history data: times of sending, hand-over to the e-mail provider, first opening, acceptance, declining and payment; the name a recipient types when accepting a quote; a reason for declining that the recipient gives;
6. technical connection data when the client page is opened, in particular the IP address, as far as needed to deliver the page and to protect the Service;
7. contents of attachments and free-text fields, which may contain any information;
8. contents of notifications to the Controller's phone: the client's name, the document number and the amount;
9. for received electronic invoices: the supplier's and the invoice's details, including address, tax numbers and bank details.

(3) Categories of data subjects.

1. the Controller's clients who are natural persons, and contact persons of clients that are companies or public bodies;
2. recipients of documents and e-mails, and persons who open a document, accept or decline a quote on the client page;
3. the Controller's suppliers and their contact persons, where the Controller receives electronic invoices through Spoonbill;
4. any other persons named in documents, notes or attachments.

(4) Special categories. Spoonbill is not designed for processing special categories of personal data (Art. 9 GDPR) or personal data relating to criminal convictions and offences (Art. 10 GDPR); the measures in Annex 1 are not tailored to them. If the Controller nevertheless enters such data, it first checks whether those measures are sufficient for them.

(5) Location. Spoonbill's servers, database and file storage are located in the European Union. Processing outside the EU and the EEA takes place only under § 9 and Annex 2.

§ 3Duration

(1) This agreement forms part of the Terms of Use. It applies to every account under § 1(3) from the conclusion of the Terms of Use and, for existing accounts, from the date this version takes effect. It applies to all Contract Data of the account, including data processed before.

(2) It runs for as long as the Terms of Use and ends when the account is deleted under § 12. It cannot be terminated separately while the Terms of Use are in force.

(3) The obligations under this agreement continue for as long as the Processor processes Contract Data.

§ 4Instructions

(1) The Processor processes Contract Data only on documented instructions from the Controller, including with regard to transfers 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. In that case, the Processor informs the Controller of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest.

(2) Documented instructions are this agreement, the Terms of Use, every setting and every action of the Controller in Spoonbill (for example sending, switching reminders on, deleting), and individual instructions in text form to the contact address under § 16(7). Anyone who uses the Controller's account may give instructions; individual instructions must come from the account's sign-in address. The Processor may decline instructions that go beyond the agreed scope of the Service if carrying them out is technically impossible or economically unreasonable; it says so without delay in text form, giving its reasons, and the Controller may then terminate the Terms of Use without notice. Subject to paragraph 3, the Processor always carries out instructions to rectify, erase, restrict the processing of or hand over Contract Data (§§ 10 and 12).

(3) If the Processor believes that an instruction infringes the GDPR or other Union or Member State data protection provisions, it immediately informs the Controller. It may suspend carrying out the instruction until the Controller confirms or changes it.

(4) The Processor does not use Contract Data for its own purposes. In particular, it does not use it for advertising, does not sell it and does not train AI models with it. The Controller instructs the Processor to derive from Contract Data figures about the Controller's use of the Service, such as the number and amounts of documents created, that contain nothing by which a data subject under § 2(3) can be identified, in particular no names, contact details, document numbers, document identifiers or invoice texts. These figures are part of the analysis of how the Service is used under § 1(2), for which the Processor is the controller; they are described in the Privacy Policy.

(5) If the Processor infringes the GDPR by determining the purposes and means of a processing operation, it is considered a controller in respect of that processing (Art. 28(10) GDPR).

§ 5Obligations of the Controller

(1) The Controller is responsible for the lawfulness of the processing, in particular for its legal basis, for informing its clients under Art. 13 and 14 GDPR, and for being entitled to use the data it enters.

(2) It informs the Processor without delay if it finds errors or irregularities in the processing.

(3) Spoonbill is not an archive. The Controller fulfils statutory retention duties for issued and received invoices, for example under § 14b of the German VAT Act (UStG) and § 147 of the German Fiscal Code (AO), itself. To do so, it keeps its own copies using the export under § 12(1).

§ 6Confidentiality

(1) The Processor ensures that all persons authorised to process Contract Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality. At present, only Dzmitry Kandratsenka personally has access to the production systems; in addition, the automated release process installs new program versions (Annex 2). If the Processor engages further persons, it commits them to confidentiality in text form before they start. The commitment continues after their work ends.

(2) The Processor takes note of the content of Contract Data only as far as necessary to provide the Service, to fix a fault, at the Controller's request or because of a legal obligation.

(3) This agreement contains no obligation of secrecy within the meaning of § 203(4), second sentence, no. 1 of the German Criminal Code (StGB), neither for the Processor nor for its Sub-processors; Spoonbill is not designed for secrets protected by professional secrecy under § 203 StGB. A Controller bound by such professional secrecy checks before use whether it may use Spoonbill for the data concerned.

§ 7Security of processing

(1) The Processor takes the technical and organisational measures (TOMs) under Art. 32 GDPR described in Annex 1.

(2) It may adapt the measures to the state of the art, provided the level of protection does not fall. It documents material changes in Annex 1 and tells the Controller about them by e-mail or in the app.

§ 8Sub-processors

(1) The Controller gives the Processor general written authorisation to engage other processors (the "Sub-processors") (Art. 28(2) GDPR). The Sub-processors listed in Annex 2 are deemed approved.

(2) The Processor informs the Controller of any intended addition or replacement of a Sub-processor at least 30 days in advance, by e-mail to the account's sign-in address or in the app, stating name, seat, task and place of processing. If a Sub-processor must be replaced at short notice for security reasons or to keep the Service running, the Processor informs the Controller without delay and gives the reason for the shorter notice. In that case the Controller may object under paragraph 3 within 30 days of being informed.

(3) The Controller may object to a change, in text form and on legitimate data protection grounds, until it takes effect. The parties then seek a solution together. Because all accounts run on the same technical platform, the Processor cannot suspend a change for individual accounts. If the Controller maintains its objection, it may terminate the Terms of Use without notice and require that its account be deleted, after its export, without the period under § 12(2). The Processor refunds pro rata any fees paid in advance directly to it for the period after termination. If the Controller does not object, the change is deemed approved.

(4) The Processor selects Sub-processors carefully. By way of a contract, it imposes on each of them the same data protection obligations as set out in this agreement, as far as they apply to that Sub-processor's service, in particular sufficient guarantees to implement appropriate technical and organisational measures (Art. 28(4), first sentence, GDPR). For the providers listed in Annex 2, this is done through the terms named there; the Processor has checked that they ensure an essentially equivalent level of protection and makes them available on request.

(5) If a Sub-processor fails to fulfil its data protection obligations, the Processor remains fully liable to the Controller for the performance of those obligations (Art. 28(4), second sentence, GDPR).

(6) Pure transmission services, for example of internet and telecommunications providers or the recipients' mail servers, and services the Controller engages itself, for example its own Stripe account for card payments, are not sub-processing within the meaning of this section.

§ 9Transfers to third countries

(1) The servers, the database and the file storage are located in the EU. Some Sub-processors process Contract Data wholly or partly outside the EU and the EEA, in particular in the United States: for sending e-mail, for notifications to the phone, in Cloudflare's upstream network, for error reports and for installing new program versions. Annex 2 states the place and the legal basis for each provider.

(2) Such a transfer takes place only on the basis of an adequacy decision under Art. 45 GDPR, for example for recipients certified under the EU-U.S. Data Privacy Framework (Implementing Decision (EU) 2023/1795), or of appropriate safeguards under Art. 46 GDPR, in particular the Commission's standard contractual clauses (Implementing Decision (EU) 2021/914, Module 3). For transfers based on standard contractual clauses, the Processor has documented the assessment under Clause 14 and makes it available on request.

(3) By accepting this agreement, the Controller instructs the transfers described in Annex 2. Further transfers to third countries take place only under § 8.

(4) If the Processor moves the server, the database or the file storage to another country, it announces this under § 8(2); § 8(3) applies accordingly.

§ 10Assistance with data subjects' rights

(1) The Controller can view, correct and export Contract Data in Spoonbill itself. It can delete drafts and clients; Spoonbill then hides them without removing them for good. Sent documents remain unchanged because they are records, and cannot be deleted one by one in the app. Contract Data is deleted for good under paragraph 2 or under § 12.

(2) Where the Controller cannot fulfil a data subject's request under Chapter III GDPR (in particular access, rectification, erasure, restriction of processing, data portability, objection) itself in Spoonbill, the Processor assists it with appropriate technical and organisational measures. This applies in particular to the final deletion of hidden drafts and clients, to the deletion of individual sent documents, for example once the Controller's retention period has ended, to the restriction of processing, and to handing over the data of a single client. The Processor carries out such an instruction without delay and at the latest within 14 days.

(3) If a data subject contacts the Processor directly, the Processor forwards the request to the Controller without delay, provided it can identify the Controller. It does not answer the request itself unless the Controller instructs it to.

§ 12Return and deletion

(1) Return. At any time and on every plan, the Controller can download all documents it has issued in one file: each as a PDF file and, where available, as an electronic invoice (XML), together with an index (CSV). The export contains received electronic invoices in the format in which they were received, with their attachments. The Controller can download individual documents one by one at any time. Contract Data that this export does not contain, such as the client directory, the Processor provides on instruction in a common machine-readable format.

(2) Deletion at the end of the agreement. The Controller requests deletion of its account in the app. From the request, the account is locked for 30 days: documents can no longer be created, changed or sent, and recurring invoices and reminders pause; only the export under paragraph 1 and withdrawing the request remain possible. When the 30 days have passed, the Processor irreversibly deletes all Contract Data of the account from the database and the file storage, including the PDF files of sent documents and the attachments; the links to the client pages stop working. Until the period ends, the Controller can get back all Contract Data under paragraph 1 (return); after that it is deleted (deletion). If the Controller gives an instruction under the last sentence of paragraph 1 during the period, the Processor deletes only after carrying it out. If a subscription of the Controller taken out through the App Store still renews on the day of deletion, the Processor does not carry out the deletion, lifts the lock and tells the Controller by e-mail; once the subscription has ended, the Controller can request deletion again.

(3) Other termination. If the Terms of Use end in another way, for example by the Processor's termination or the discontinuation of the Service, the Processor announces the deletion at least 30 days in advance by e-mail and keeps the Contract Data available for export under paragraph 1 until then. If it has to lock the account earlier for security reasons, it provides the Contract Data on instruction during that time. It deletes earlier only where a law requires it.

(4) Copies. Contract Data in server logs is deleted at the latest 30 days after it arises, in the database's binary logs at the latest 30 days after it arises, and in backup copies at the latest 366 days after they are made. Error reports at the Sub-processor Slack are deleted at the latest 90 days after they arrive, and send logs at the e-mail provider under that provider's terms. Until then these copies are used only for restoring data or investigating a security incident. If a backup is restored, the Processor deletes again any Contract Data that had already been deleted.

(5) No storage obligation. The Processor is under no obligation under Union or Member State law to store Contract Data after the end of the agreement. The Controller fulfils its own retention duties with its export (§ 5(3)).

(6) On request, the Processor confirms the deletion in text form.

(7) E-mails and files that recipients have already received or downloaded are outside the Processor's control.

§ 13Evidence and audits

(1) The Processor makes available to the Controller all information necessary to demonstrate compliance with the obligations under Art. 28 GDPR, in particular this agreement with Annex 1 and Annex 2 and, where available, certificates and audit reports of the Sub-processors.

(2) The Processor allows for and contributes to audits, including inspections, conducted by the Controller or by an auditor it mandates who is bound to confidentiality and is not a competitor of the Processor. Audits must be announced at least 14 days in advance, take place during normal business hours, must not disrupt operations disproportionately, and as a rule take place no more than once per calendar year; for a specific reason, such as after a personal data breach or at the request of a supervisory authority, also more often.

(3) As the Processor operates no data centres of its own, audits take place primarily by reviewing documents and remotely, and on request at the Processor's seat. For the Sub-processors' data centres, their certificates and audit reports suffice.

(4) Each party bears its own costs of an audit.

(5) The Processor cooperates with supervisory authorities and assists the Controller with their inspections.

(6) The Processor maintains a record of all categories of processing activities carried out on behalf of controllers under Art. 30(2) GDPR.

§ 14Third-party requests and data access by the tax authorities

(1) If an authority or another third party asks the Processor for Contract Data, the Processor refers it to the Controller and informs the Controller without delay, as far as legally permitted. It discloses Contract Data only if legally obliged to, and then only to the extent required.

(2) If the Controller informs a German tax authority that its data is held by the Processor (§ 147(6), second sentence, AO), the Processor grants that authority data access under that provision, as far as the data is still stored, once the Controller has confirmed this to it in text form. Under § 147(6), third sentence, AO, the Controller bears the costs.

§ 15Liability

(1) Towards data subjects, the parties are liable under Art. 82 GDPR.

(2) The liability rules of the Terms of Use also apply to the settlement between the parties under Art. 82(5) GDPR. Liability towards data subjects remains unaffected.

§ 16Final provisions

(1) Precedence. Where this agreement and the Terms of Use conflict, this agreement prevails as far as the protection of personal data is concerned. Where this agreement and its annexes conflict, the main text prevails.

(2) Form. This agreement is in writing, in electronic form (Art. 28(9) GDPR). It forms part of the Terms of Use and is concluded with them: whoever agrees to the Terms of Use when signing up also concludes this agreement. The Processor confirms in text form on request which version applies to an account. The current version is available at spoonbill.app/en/avv and can be saved and printed.

(3) Changes. The Processor may change this agreement if the law, case law or a supervisory authority requires it, or if a change to the Service makes it necessary, and only if the level of protection for Contract Data does not fall as a result. It announces changes at least 30 days before they take effect, by e-mail or in the app, and points out the consequence of not objecting. If the Controller does not object in text form before the change takes effect, the change is deemed accepted. If it objects, the previous version continues to apply to it; either party may then terminate the Terms of Use with effect from the date the change takes effect. Changes to Annex 2 follow § 8.

(4) Severability. If a provision of this agreement is invalid, the remaining provisions remain valid. The invalid provision is replaced by the rule of the GDPR that comes closest to its purpose.

(5) Governing law and jurisdiction. This agreement is governed by the law of Portugal, excluding its conflict-of-law rules; the GDPR takes precedence. The courts of Porto, Portugal have exclusive jurisdiction for disputes between the parties. The rights of data subjects, in particular under Art. 79 GDPR, remain unaffected.

(6) Language. For Controllers established in Germany, Austria, Switzerland or Liechtenstein the German version is binding; for all others the English version.

(7) Contact and supervision. The Controller sends instructions, objections, notifications and data protection enquiries to feedback@spoonbill.app. The Processor has not appointed a data protection officer; it is not obliged to under Art. 37 GDPR. The supervisory authority competent for the Processor is the Comissão Nacional de Proteção de Dados (CNPD), Lisbon, Portugal.

(8) Text form. Where this agreement requires text form, an e-mail suffices.

Annex 1Technical and organisational measures (Art. 32 GDPR)

1. Confidentiality

Physical access control

The Processor operates no data centres of its own. The server and the database run at netcup GmbH in Germany (Nuremberg data centre), the file storage and the database backups at Cloudflare in storage whose data is restricted to the EU jurisdiction. Physical security of the data centres follows those providers' security attestations.

System access control

Signing in to Spoonbill uses Firebase Authentication (with Google, with Apple, or with an e-mail address and password).
Every request to the interface must carry a valid sign-in token from Firebase, which the server checks on every request. Reachable without a sign-in token are only the client page (see data access control), registration, the public price list, error reports from the browser, the server's health check, and notifications from Stripe and Apple, whose signature the server checks.
The production server can be administered only over SSH with a key; password login is switched off. Only the owner and the automated release process (Annex 2), which installs new program versions, hold keys.
The database and the application services are reachable only through the server's local interface. Reachable from outside are only the web server, over HTTPS (it only redirects requests over HTTP to HTTPS), and the SSH access for administration.
Credentials for the database, the file storage and the e-mail service are kept in configuration files outside the source code.
The owner's work computer is fully encrypted.

Data access control

Every record belongs to exactly one account, and every query is limited to the account of the signed-in user. For another account's records, the server answers as if they did not exist. Automated tests check this for invoices, quotes, attachments, notifications and the overview.
There is no administration interface through which other accounts' data can be viewed.
The client page can only be reached through a personal link with 192 bits of randomness. Requests to the client page, registration, the price list and browser error reports are rate-limited.

Separation control

The accounts' data are logically separated (see data access control).
The production database is separate from development and test systems. The file storage and the access to the e-mail service are currently shared by development and production.
Development and test systems cannot send e-mail to real recipients, only to explicitly allowed test addresses.
Spoonbill's usage analytics receive no names, contact details or invoice texts of clients. The client page loads no analytics or advertising tools.

Encryption

All connections between browser or app and Spoonbill are encrypted with TLS; the browser is instructed to use encrypted connections only (HSTS). The connections to the file storage and to the e-mail provider are also encrypted.
The file storage encrypts all files and their metadata at rest with AES-256 (GCM).

2. Integrity

Transfer control

E-mails to recipients go out only on an action of the Controller or according to its settings; payment reminders can be switched off for the account and for each client.
All transfers are encrypted (see encryption).
Error reports to the operator are cleaned automatically before sending: e-mail addresses, links to client pages, tokens, identifiers in paths and query parameters are removed, and the account appears only under its internal identifier. Client names can exceptionally remain as part of an error text; that is why the recipient is listed in Annex 2.
The Controller can set notifications on its phone to show no client names and amounts.

Input control

Each invoice has a history (created, changed, issued, sent, opened, paid and further events) that is only ever appended to and never changed. For quotes, the times of sending, first opening, acceptance and declining are recorded.
Sent documents cannot be changed: the server refuses every change, and Spoonbill writes each file only once and overwrites no stored file.

3. Availability and resilience

Requests to Spoonbill's addresses pass through Cloudflare's upstream network, which protects against overload attacks. Requests without sign-in are rate-limited (see data access control).
The application services continuously check their own health and are restarted automatically on failure.
Availability is checked regularly from outside; outages trigger an alert.
E-mails to recipients are retried until the e-mail provider has accepted them; a failure is shown to the Controller.
Backups: the database is backed up daily, encrypted, outside the server in the EU (Cloudflare R2, storage in the EU jurisdiction); the key that decrypts it is not on the server. Daily backups are kept for 31 days, the one from the first of each month for 366 days; no backup can be deleted or overwritten before 30 days have passed. Restoring is tested at least quarterly.

4. Recoverability

Program code and the configuration of the application services are versioned. Every released version can be installed again.
For restoring data, see backups under number 3.

5. Regular review

Security-relevant properties are pinned by automated tests that run when the parts concerned change: the separation of accounts in the areas named under data access control, the complete deletion of an account across all tables, that Spoonbill does not overwrite stored files, and the cleaning of error reports.
This annex is reviewed at least once a year and with every change of Sub-processors.

6. Data protection by default

Notifications to the phone are active only if the Controller switches them on.
The client page loads no analytics or advertising tools, and whether an e-mail was opened is not measured.

7. Processor control

Sub-processors are engaged only under § 8 and bound by contract under Art. 28(4) GDPR.
Contract Data is not used for advertising, not sold and not used to train AI models.

8. Deletion

An account is deleted completely 30 days after the deletion request: all tables, all stored files and the sign-in account. An automated test fails if a new table is not covered by the deletion.
Uploaded attachments never assigned to a document are deleted after 7 days.
Server logs are deleted after 30 days at the latest, the database's binary logs after 30 days (§ 12(4)).
Device tokens for notifications are deactivated when the user signs out on the device and deleted with the account.

Annex 2Sub-processors

netcup GmbH, Emmy-Noether-Straße 10, 76131 Karlsruhe, Germany — Task: Running the server and the database — Contract Data concerned: all Contract Data except files — Place of processing: Germany (Nuremberg data centre) — Basis for the transfer: no transfer to a third country
Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA — Task: a) File storage (R2) for PDF files, attachments and logos, and for the encrypted database backups; b) upstream network (reverse proxy): Cloudflare ends the encrypted connection in its data centre, checks the request and forwards it to the server over a new encrypted connection; the transmitted data is readable by Cloudflare while it does so — Contract Data concerned: a) stored files and, encrypted, all Contract Data in the database; b) all transmitted data in transit — Place of processing: a) EU (storage in the EU jurisdiction); b) the Cloudflare data centre nearest to the requester, possibly outside the EU — Basis for the transfer: adequacy decision (EU-U.S. Data Privacy Framework) and standard contractual clauses (Cloudflare's data processing terms)
Infomaniak Network SA, Rue Eugène-Marziano 25, 1227 Les Acacias, Switzerland — Task: Sending e-mails to recipients; receiving delivery failure notices — Contract Data concerned: recipient's name and e-mail address, content of the e-mail, PDF file and attachments — Place of processing: Switzerland — Basis for the transfer: adequacy decision of the European Commission for Switzerland (2000/518/EC)
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, with Google LLC, USA — Task: Firebase Cloud Messaging: delivering notifications to the Controller's phone — Contract Data concerned: text of the notification (client name, document number, amount), device token — Place of processing: worldwide, including the USA — Basis for the transfer: adequacy decision (EU-U.S. Data Privacy Framework, Google LLC) and standard contractual clauses (Firebase Data Processing and Security Terms)
Slack Technologies Limited, Salesforce Tower, 60 R801, North Dock, Dublin, Ireland, with Slack Technologies, LLC, USA — Task: Delivering technical error reports to the operator — Contract Data concerned: error reports from which e-mail addresses, links, identifiers and tokens are removed beforehand; Contract Data only exceptionally, as a fragment of an error text — Place of processing: USA — Basis for the transfer: adequacy decision (EU-U.S. Data Privacy Framework, through Salesforce) and standard contractual clauses (Slack's Data Processing Addendum)
Circle Internet Services, Inc. ("CircleCI"), 2261 Market Street #22561, San Francisco, CA 94114, USA — Task: Automated installation of new program versions on the server; holds administrative access to the server for this — Contract Data concerned: none in normal operation; technical access to all Contract Data on the server — Place of processing: USA — Basis for the transfer: adequacy decision (EU-U.S. Data Privacy Framework) and standard contractual clauses (CircleCI's Data Processing Addendum)

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