Probata

Draft — not yet reviewed by a lawyer.

Data processing agreement

Last updated [DATE]

This agreement forms part of the terms of service between [ENTITY], [ADDRESS] (the processor, "we") and the organisation using Probata (the controller, "you"). It covers the personal data of your staff and others that you put into Probata.

What we process

  • People: your staff and anyone you invite, and people named in evidence you upload.
  • Data: names, work email addresses, roles and teams, objectives, check-ins, evidence files, links and notes, reviews, and audit records.
  • Purpose: to run Probata for you, for as long as your organisation uses it.

Our commitments

  • We process your data only on your documented instructions, which are these terms and the way you use Probata.
  • Everyone at [ENTITY] who can reach your data is bound to confidentiality.
  • Our staff can't see your organisation's content unless you grant time-limited support access, which is logged.
  • We help you answer requests from people exercising their rights, and with security reviews you need to carry out.
  • We tell you without undue delay, and within 72 hours, after becoming aware of a breach affecting your data.

Security

  • Encrypted connections only (HTTPS), and secure, first-party sign-in cookies.
  • Each organisation's data is kept apart by checks in the application and by row-level security in the database, tested automatically.
  • Optional two-step sign-in, which owners can make compulsory.
  • Passwords stored as hashes and checked against known breaches.
  • An audit log of changes in each organisation.
  • Daily encrypted backups with a second provider, with restores tested monthly.

Sub-processors

You authorise these providers. We will tell owners at least 30 days before adding or replacing one, and you may object.

  • Hetzner Online GmbH (Germany or Finland): servers and file storage.
  • [BACKUP PROVIDER] (EU): encrypted backups.
  • [EMAIL PROVIDER]: email delivery.
  • Cloudflare, Inc.: network protection.

Location

Your data is stored in the European Union. We will not move it outside the EU without telling you first and putting proper safeguards in place.

When the agreement ends

An owner can export everything (data and files) at any time. When the organisation is deleted, its data is removed from the live service immediately and from backups within 30 days.

Audits

We will give you the information you reasonably need to show that this agreement is being followed. Write to [CONTACT EMAIL].