Parties
This Data Processing Agreement (DPA) is entered into between Assetify (the "Data Processor") and the Client (the "Data Controller").
Scope
The Processor processes personal data on behalf of the Controller solely for the purposes of providing the Assetify platform — including asset management, license tracking, contract management, and related services.
The Processor does not process student or patient data directly. It may process organizational data including staff information, device assignments, and usage logs.
Data subject categories
Personal data may include information about employees, IT staff, contractors, and other individuals identified in asset or contract records. This does not include direct processing of student or patient data unless explicitly agreed in writing.
Data categories
The following categories of personal data may be processed under this DPA:
Duration
This DPA remains in effect for the duration of the service agreement and continues until all personal data is deleted or returned per § 09.
Processor obligations
The Processor commits to the following, consistent with GDPR Article 32:
Sub-processors
The Processor may engage sub-processors for hosting, backups, and integrations. The Controller will be notified of any sub-processor changes with at least 30 days notice.
The Controller may object to any new sub-processor on reasonable grounds.
Data security
- Data is stored in European Union data centers in compliance with GDPR data residency requirements.
- Encryption is applied both in transit and at rest.
- Access is restricted to authorized personnel with role-based access controls.
- Regular penetration testing and vulnerability assessments are conducted.
- Incident response procedures are documented and tested.
Data deletion and return
Upon termination of the service agreement, the Controller may request deletion or return of personal data. The Processor follows this timeline:
International transfers
All data is processed and stored within the European Union. No transfers outside the EEA occur without explicit written consent and appropriate safeguards.
Data breach notification
The Processor shall notify the Controller without undue delay, and in any case within 24 hours, upon becoming aware of a personal data breach. The Processor shall provide all information necessary for the Controller to meet legal notification obligations.
Data subject rights
The Processor shall, at the Controller's request, assist in fulfilling data subject rights:
Audit and compliance
The Processor shall make available all information necessary to demonstrate compliance with GDPR and allow for audits and inspections by the Controller or a third-party auditor upon reasonable notice.
Liability
The Processor's liability for breaches of this DPA shall not exceed the fees paid by the Controller in the twelve months preceding the breach, unless the breach involves a data protection violation.
Governing law
This DPA shall be governed by the laws of the Netherlands and the GDPR.
Amendments
This DPA may be amended to reflect changes in GDPR requirements, data processing activities, or security standards. Material amendments require written consent from the Controller.