Aptabase Data Processing Agreement

This Data Processing Agreement (”DPA”) is incorporated into and forms part of the Aptabase Terms of Service (the ”Agreement”) between the customer using the Aptabase Cloud service (the ”Controller” or ”Customer”) and Technov Solutions SRL, a company incorporated in Romania (the ”Processor” or ”Aptabase”).

This DPA reflects the parties’ agreement with regard to the processing of personal data by Aptabase on behalf of the Customer under Article 28 of Regulation (EU) 2016/679 (”GDPR”). It is based on the Standard Contractual Clauses adopted by the European Commission under Article 28(7) GDPR (Commission Implementing Decision (EU) 2021/915).

This DPA is automatically executed and legally binding upon the Customer’s acceptance of the Agreement or use of the service. No signature is required. Customers who need a countersigned copy for their records may request one at support@aptabase.com.

Section I

Clause 1 — Purpose and scope

The purpose of these Clauses is to ensure compliance with Article 28(3) and (4) of the GDPR.
The Controller and the Processor listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of the GDPR.
These Clauses apply to the processing of personal data as specified in Annex II.
Annexes I to IV are an integral part of the Clauses.
These Clauses are without prejudice to obligations to which the Controller is subject by virtue of the GDPR.
These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of the GDPR.

Clause 2 — Invariability of the Clauses

The parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.
This does not prevent the parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards, provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3 — Interpretation

Where these Clauses use the terms defined in the GDPR, those terms shall have the same meaning as in that Regulation.
These Clauses shall be read and interpreted in the light of the provisions of the GDPR.
These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in the GDPR or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4 — Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Section II — Obligations of the parties

Clause 5 — Description of processing

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the Controller, are specified in Annex II.

Clause 6 — Obligations of the parties

6.1 Instructions

The Processor shall process personal data only on documented instructions from the Controller, unless required to do so by Union or Member State law to which the Processor is subject. In this case, the Processor shall inform the Controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the Controller throughout the duration of the processing of personal data. These instructions shall always be documented.
The Customer’s acceptance of the Agreement, this DPA, and the Customer’s configuration of the service (including the choice of hosting region and the events the Customer chooses to send) constitute the Controller’s complete documented instructions to the Processor. Additional instructions require prior written agreement of both parties.
The Processor shall immediately inform the Controller if, in the Processor’s opinion, instructions given by the Controller infringe the GDPR or applicable Union or Member State data protection provisions.

6.2 Purpose limitation

The Processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the Controller.

6.3 Duration of the processing of personal data

Processing by the Processor shall only take place for the duration specified in Annex II.

6.4 Security of processing

The Processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.
The Processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The Processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

6.5 Sensitive data

The service is not designed or intended for the processing of special categories of personal data (Article 9 GDPR) or personal data relating to criminal convictions and offences (Article 10 GDPR). The Agreement prohibits the Customer from submitting such data (as well as any personal data within custom event properties) to the service. If such data were nevertheless processed, the Processor shall apply specific restrictions and/or additional safeguards.

6.6 Documentation and compliance

The parties shall be able to demonstrate compliance with these Clauses.
The Processor shall deal promptly and adequately with inquiries from the Controller about the processing of data in accordance with these Clauses.
The Processor shall make available to the Controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from the GDPR. At the Controller’s request, the Processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the Controller may take into account relevant certifications held by the Processor.
The Controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the Processor and shall, where appropriate, be carried out with reasonable notice.
The parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

6.7 Use of sub-processors

The Processor has the Controller’s general authorisation for the engagement of sub-processors from the agreed list in Annex IV. The Processor shall specifically inform in writing the Controller of any intended changes of that list through the addition or replacement of sub-processors at least 30 days in advance, thereby giving the Controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). Notice shall be given by e-mail to the Controller’s registered account address and/or by updating the list published at this page. The Processor shall provide the Controller with the information necessary to enable the Controller to exercise the right to object.
Where the Processor engages a sub-processor for carrying out specific processing activities (on behalf of the Controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the Processor in accordance with these Clauses. The Processor shall ensure that the sub-processor complies with the obligations to which the Processor is subject pursuant to these Clauses and to the GDPR.
At the Controller’s request, the Processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the Controller. To the extent necessary to protect business secrets or other confidential information, including personal data, the Processor may redact the text of the agreement prior to sharing the copy.
The Processor shall remain fully responsible to the Controller for the performance of the sub-processor’s obligations in accordance with its contract with the Processor. The Processor shall notify the Controller of any failure by the sub-processor to fulfil its contractual obligations.
The Processor shall agree a third-party beneficiary clause with the sub-processor whereby — in the event the Processor has factually disappeared, ceased to exist in law or has become insolvent — the Controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

6.8 International transfers

Any transfer of data to a third country or an international organisation by the Processor shall be done only on the basis of documented instructions from the Controller or in order to fulfil a specific requirement under Union or Member State law to which the Processor is subject and shall take place in compliance with Chapter V of the GDPR. The Customer’s selection of the US hosting region (us.aptabase.com) constitutes a documented instruction to process the personal data on infrastructure located in the United States, subject to the safeguards described in Annex IV. Customers selecting the EU hosting region (eu.aptabase.com) have their analytics data processed and stored within the European Union.
The Controller agrees that where the Processor engages a sub-processor in accordance with Clause 6.7 for carrying out specific processing activities (on behalf of the Controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of the GDPR, the Processor and the sub-processor can ensure compliance with Chapter V of the GDPR by using standard contractual clauses adopted by the Commission in accordance with Article 46(2) of the GDPR, provided the conditions for the use of those standard contractual clauses are met, or another valid transfer mechanism under Chapter V of the GDPR (such as an adequacy decision, including the EU-U.S. Data Privacy Framework where the recipient is certified under it).

Clause 7 — Assistance to the controller

The Processor shall promptly notify the Controller of any request it has received from a data subject. It shall not respond to the request itself, unless authorised to do so by the Controller.
The Processor shall assist the Controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling these obligations, the Processor shall comply with the Controller’s instructions. Note on the nature of the processing: as described in Annex II, the Processor does not store direct identifiers of the Controller’s end users. Stored analytics data cannot be attributed to a specific data subject by the Processor without additional information that the Processor does not hold. In accordance with Article 11(2) GDPR, Articles 15 to 20 GDPR may not apply to such data, except where the data subject provides additional information enabling their identification; the Processor shall nevertheless provide reasonable assistance to the Controller in demonstrating this to data subjects and supervisory authorities.
In addition to the Processor’s obligation to assist the Controller pursuant to paragraph 2, the Processor shall furthermore assist the Controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the Processor:
1. the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a “data protection impact assessment”) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;
2. the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the Controller to mitigate the risk;
3. the obligation to ensure that personal data is accurate and up to date, by informing the Controller without delay if the Processor becomes aware that the personal data it is processing is inaccurate or has become outdated;
4. the obligations in Article 32 of the GDPR.
The parties shall set out in Annex III the appropriate technical and organisational measures by which the Processor is required to assist the Controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 8 — Notification of personal data breach

In the event of a personal data breach, the Processor shall cooperate with and assist the Controller for the Controller to comply with its obligations under Articles 33 and 34 of the GDPR, where applicable, taking into account the nature of processing and the information available to the Processor.

8.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the Controller, the Processor shall assist the Controller:

in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the Controller has become aware of it, where relevant (unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);
in obtaining the following information which, pursuant to Article 33(3) of the GDPR, shall be stated in the Controller’s notification, and must at least include:
1. the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
2. the likely consequences of the personal data breach;
3. the measures taken or proposed to be taken by the Controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.
Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.
in complying with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

8.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the Processor, the Processor shall notify the Controller without undue delay after the Processor having become aware of the breach. Such notification shall contain, at least:

a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);
the details of a contact point where more information concerning the personal data breach can be obtained;
its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

Section III — Final provisions

Clause 9 — Non-compliance with the Clauses and termination

Without prejudice to any provisions of the GDPR, in the event that the Processor is in breach of its obligations under these Clauses, the Controller may instruct the Processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The Processor shall promptly inform the Controller in case it is unable to comply with these Clauses, for whatever reason.
The Controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:
1. the processing of personal data by the Processor has been suspended by the Controller pursuant to point 1 and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;
2. the Processor is in substantial or persistent breach of these Clauses or its obligations under the GDPR;
3. the Processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to the GDPR.
The Processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the Controller that its instructions infringe applicable legal requirements in accordance with Clause 6.1 point 3, the Controller insists on compliance with the instructions.
Following termination of the contract, the Processor shall, at the choice of the Controller, delete all personal data processed on behalf of the Controller and certify to the Controller that it has done so, or return all the personal data to the Controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the Processor shall continue to ensure compliance with these Clauses. Unless the Controller requests otherwise in writing before or upon termination, deletion of the Customer’s apps or account constitutes the Controller’s choice of deletion, and associated analytics data will be permanently deleted.

Clause 10 — Governing law

These Clauses and any dispute arising from them shall be governed by the laws of Romania, without prejudice to any mandatory provisions of the GDPR or of the data protection law of the Member State where the Controller is established, and without regard to conflict of law provisions.

Annex I — List of parties

Controller: the Customer — the natural or legal person that has accepted the Agreement and uses the Aptabase Cloud service, as identified by the name, e-mail address and (where provided) company details registered in the Customer’s Aptabase account. The Customer’s account registration details are deemed to be the Controller’s identity and contact details for the purposes of these Clauses.

Processor:

Technov Solutions SRL
Str. Fabricii, Nr. 47
Bucharest
Romania
Trade Register No.: J40/7232/2017
CUI: 37597235
Contact: office@technov.ro

Annex II — Description of the processing

Categories of data subjects whose personal data is processed:

End users of the Customer’s applications (mobile, desktop or web) in which the Customer has embedded an Aptabase SDK or which otherwise send events to the service.

Note: personal data relating to the Customer itself (account name, e-mail address, billing details) is processed by Technov Solutions SRL as an independent controller and is governed by the Privacy Policy, not by this DPA.

Categories of personal data processed:

IP address and User-Agent string of the end user’s device — processed transiently, in memory, at the moment of event ingestion, solely to (a) derive coarse geolocation (country and region) and (b) compute a pseudonymous daily user identifier. The IP address and User-Agent are not stored with the analytics data.
Pseudonymous daily user identifier — a salted hash computed as SHA(IP address + User-Agent + daily rotating salt). Salts are unique per application, rotated every 24 hours and permanently deleted, making it impossible to correlate the identifier across days or across applications, or to reverse it to an IP address after salt deletion.
Telemetry event data — event name, timestamp, session identifier, application version, SDK version, operating system name and version, device locale, coarse geolocation (country/region), and custom event properties defined by the Customer. The Agreement prohibits the Customer from including personal data in event names or custom properties.

Sensitive data processed: none. The processing of special categories of personal data (Article 9 GDPR) and of data relating to criminal convictions and offences (Article 10 GDPR) is not intended and is prohibited under the Agreement (see Clause 6.5).

Nature of the processing: collection, pseudonymisation, aggregation, storage, retrieval, analysis and presentation of usage analytics data; hosting and related technical support.

Purpose(s) for which the personal data is processed on behalf of the controller: providing the Customer with privacy-first, aggregate usage analytics for its applications, as described in the Agreement.

Duration of the processing: for the duration of the Agreement. Telemetry event data is retained for a maximum of five (5) years from collection, or until deletion of the corresponding app or Customer account, whichever occurs first. IP addresses and User-Agent strings are processed only transiently at ingestion and are not retained. Daily salts are deleted after 24 hours.

For processing by sub-processors: subject matter, nature and duration as set out above and in Annex IV (infrastructure hosting, analytics data storage and querying, transactional e-mail delivery), each for the duration of the Agreement.

Annex III — Technical and organisational measures

The Processor implements and maintains, as a minimum, the following technical and organisational measures pursuant to Article 32 GDPR:

Pseudonymisation and data minimisation

No device identifiers, advertising identifiers, hardware identifiers or persistent user identifiers are collected by the Aptabase SDKs.
End-user IP addresses and User-Agent strings are processed transiently in memory at ingestion and are not written to the analytics store.
Daily user identifiers are derived by strong salted hashing; salts are unique per application, rotated every 24 hours and permanently purged by an automated job, after which re-identification by the Processor is not possible.
Geolocation is reduced to country/region granularity before storage.

Encryption

All data in transit is encrypted using TLS (HTTPS enforced on all endpoints, including event ingestion and the dashboard).
Data at rest is encrypted using the encryption-at-rest facilities of the infrastructure and analytics-database sub-processors listed in Annex IV.

Confidentiality, integrity, availability and resilience

Analytics data is logically segregated per application via unique application keys; customers can only query data for applications they own.
The service is operated in two independent regional deployments (EU and US); a Customer’s analytics data is stored only in the region selected by the Customer.
Access to production systems is restricted to authorised personnel on a need-to-know basis, protected by strong authentication (including multi-factor authentication) and role-based access controls.
Personnel and contractors with access to personal data are bound by confidentiality obligations.
Automated backups and monitoring/alerting are in place for production systems.

Processes for testing, assessing and evaluating effectiveness

The Aptabase codebase is open source and publicly auditable.
Security-relevant changes are subject to code review; dependencies are monitored for known vulnerabilities.
Technical and organisational measures are reviewed periodically and after significant changes to the service.

Measures for assistance to the Controller (Clauses 7 and 8)

Contactable support channel (support@aptabase.com) for data-subject-request and audit inquiries.
Breach detection via infrastructure monitoring; documented internal incident-response process, including notification of affected customers without undue delay.
Data export functionality enabling the Controller to retrieve its analytics data; deletion of an app or account permanently removes the associated analytics data.

Annex IV — List of sub-processors

The service is operated as two fully independent regional deployments (“scale units”): EU (eu.aptabase.com) and US (us.aptabase.com). All sub-processors are engaged separately per scale unit: analytics data of EU-region customers is processed and stored exclusively within the European Union, and analytics data of US-region customers exclusively within the United States. No analytics data flows between the two scale units.

The Controller has authorised the use of the following sub-processors:

Sub-processor	Service	Location / region	Transfer safeguard
Tinybird Data S.L. (Spain)	Analytics database (event storage and querying)	EU scale unit: European Union · US scale unit: United States	EU region: data remains in the EU — no third-country transfer. US region: processing in the US on the Controller’s documented instruction (Clause 6.8); SCCs (2021/914) and/or EU-U.S. Data Privacy Framework as applicable
Amazon Web Services EMEA SARL	Cloud hosting and infrastructure (application servers, event ingestion, PostgreSQL database, transactional e-mail via Amazon SES)	EU scale unit: European Union · US scale unit: United States	EU region: data remains in the EU — no third-country transfer. US region: processing in the US on the Controller’s documented instruction (Clause 6.8); SCCs (2021/914) and/or EU-U.S. Data Privacy Framework as applicable

Note: payment processing for Customer subscriptions is performed by a payment provider acting in relation to the Customer’s own billing data (controller-side) and is listed in the Privacy Policy; it does not process end-user analytics data and is therefore not a sub-processor under this DPA.

This list is also maintained at this page. Changes are notified in accordance with Clause 6.7.

This Data Processing Agreement is based on the Standard Contractual Clauses annexed to Commission Implementing Decision (EU) 2021/915 of 4 June 2021.

Last updated: July 24, 2026