Data Processing Agreement
Private-pilot processing terms between the customer (controller) and the configured Rookglint operator (processor).
Parties and instructions
Processor: Not yet specified, Not yet specified, contact [email protected]. The customer controlling a connected site/app instructs the processor to collect and present the agreed analytics and, where enabled, enquiry data for the duration of the service. The controller chooses authorised sites, goals, retention and users. There is no resale or independent visitor profiling. Optional Stripe analytics, team access, growth experiments and owner-approved advertising controls are separate documented customer instructions; advertising destinations process data under the customer’s own approved configuration.
Data and people
Data subjects are customer website/app visitors and people submitting enquiries. Data categories are those described in the Privacy Notice: minimised event metadata, pseudonymous session references, optional reported transaction amounts and submitted enquiry contact details. Special-category data and sensitive/free-form analytics properties are prohibited.
Processor duties
Process only documented lawful instructions, including for transfers; ensure authorised persons are bound to confidentiality; apply appropriate technical and organisational safeguards; notify the controller if an instruction appears unlawful; assist with requests, security incidents, impact assessments and supervisory inquiries to the extent required. Inform the controller without undue delay after becoming aware of a personal data breach and provide available details.
Security measures
Tenant-scoped access checks, hashed passwords, HttpOnly account sessions, exact-Origin browser collection, DNS domain verification, hashed server keys, minimised event schemas, input limits and retention/deletion tools are implemented. Production TLS, infrastructure access controls, backups, monitoring, restore procedures and regular effectiveness reviews must be configured and verified for the actual host before public operation.
Subprocessors and transfers
Current configuration: Local development only; production providers not selected. Region: Local development machine; production region not selected. The processor must provide the actual list before production, impose equivalent contractual duties, remain responsible for subprocessor obligations and give advance notice of changes with an opportunity to object. Any restricted transfer requires a valid applicable safeguard; no blanket permission to unrestricted international transfers is granted.
Assistance, audit and end of processing
The processor supplies necessary information to demonstrate compliance and allows reasonable controller audits, subject to confidentiality and proportionate safeguards. At the controller’s choice at termination, return data through export or erase it, except legally required retention. Active data deletion is available in settings. Backup expiry, restore-time deletion enforcement and any retained-record schedule must be agreed before production use.
Acceptance and status
The workspace owner accepts the current DPA version when connecting a site. Acceptance version and time are recorded. This draft becomes usable only with identified parties, actual subprocessors and verified operational measures. It supplements the Terms and does not waive statutory duties or visitor rights.
Source framework: GDPR and EDPB consent guidance. Customer-specific legal assessment and production review remain necessary.