Data Processing Agreement
Last updated: 26 July 2026
This DPA applies where a customer organization acts as controller and the Provider processes Customer Data on the customer’s behalf. If the English and Lithuanian versions conflict, the Lithuanian version prevails.
1. Parties and Effect
This Data Processing Agreement (“DPA”) forms part of the Terms of Service between the customer organization (“Customer”) and Jonas Liubinas (“Provider”). It applies to the extent the Provider processes Customer Data on behalf of the Customer as a processor under applicable data protection law.
If this DPA conflicts with the Terms of Service on data protection matters, this DPA prevails for those matters.
2. Subject Matter and Duration
The subject matter of the processing is the provision, maintenance, support, security, and hosting of PLN System for the Customer.
Processing continues for the duration of the customer relationship and any limited post-termination retention period described in the Terms, this DPA, or applicable law.
3. Nature and Purpose of Processing
The Provider processes Customer Data only to provide the Service and related support, security, maintenance, backup, restoration, troubleshooting, and service administration on behalf of the Customer.
4. Categories of Data Subjects and Personal Data
Depending on the Customer’s use of the Service, data subjects may include Customer representatives, administrators, employees, contractors, field users, clients, contact persons, invoice recipients, and other persons whose data the Customer chooses to enter into the Service.
- Identity and contact data, such as names, emails, phone numbers, addresses, and company details.
- Operational records, such as task, schedule, invoice, contact, chat, file, attachment, and activity information.
- User access and role data within the customer organization.
- Other Customer Data intentionally submitted to the Service by the Customer or its users.
5. Customer Obligations
The Customer is responsible for determining the lawful basis and purposes of Customer Data processing, providing required notices, honoring data subject rights, and ensuring that Customer Data may lawfully be transferred to and processed through the Service.
The Customer must not instruct the Provider to process Customer Data in a way that violates applicable law.
6. Provider Obligations
The Provider will process Customer Data only on documented instructions from the Customer, unless otherwise required by applicable law.
The Provider will ensure that persons authorized to process Customer Data are subject to confidentiality obligations and will implement reasonable technical and organizational security measures appropriate to the risks of the processing.
7. Subprocessors
The Customer authorizes the Provider to use subprocessors where reasonably necessary to provide the Service.
- Hetzner for European hosting infrastructure.
- Backblaze B2 for European attachment and blob storage.
- Other subprocessors, if added in the future, only to the extent reasonably necessary for operating the Service and subject to data protection obligations appropriate to the processing.
8. Security and Incident Handling
The Provider will maintain reasonable security measures, including SSL/TLS in transit, access controls, authentication and session controls, logging/monitoring, and database backups.
If the Provider becomes aware of a personal data breach affecting Customer Data, the Provider will notify the Customer without undue delay after becoming aware, taking into account the information reasonably available at the time.
9. Assistance
Taking into account the nature of processing and the information available to the Provider, the Provider will provide reasonable assistance to the Customer with data subject requests, security obligations, breach notifications, impact assessments, and supervisory authority cooperation, to the extent required by applicable law and reasonably possible.
10. Return and Deletion
Upon termination or deletion of the customer organization, the Provider will delete Customer Data in accordance with the Service deletion process, subject to any legally required retention and limited rolling backup retention.
The current deletion flow provides a 7-day grace period after a customer-initiated organization deletion request, followed by final deletion, with deleted data potentially remaining in rolling backups for up to an additional 7 days.
Deleting an individual user account does not by itself delete Customer Data controlled by the customer organization. On successful individual account deletion, the Provider removes the user’s sign-in identity and releases the email address, then anonymizes the user’s name, phone number, and profile picture within 90 days. Organization-controlled work records remain subject to the customer’s instructions, this DPA, and applicable retention law.
If the Provider suspends or terminates the Service for non-payment, material breach, security, or legal reasons, the Provider may retain Customer Data for a limited period reasonably necessary to administer the suspension or termination, handle cure, disputes or refunds, protect the Service, comply with law, and complete deletion.
11. Audits and Information
The Provider will make available information reasonably necessary to demonstrate compliance with this DPA. Any audit or inspection must be reasonable, limited in scope, protective of other customers and confidential information, and carried out in a way that does not unreasonably disrupt the Service.
12. International Transfers and Governing Law
The Provider stores Customer Data primarily in Europe. If Customer Data is transferred outside the EEA, the Provider will rely on applicable lawful transfer mechanisms required under data protection law.
Where the Provider gives notice about material changes to the Terms of Service, Privacy Policy, or this DPA, the Provider may send that notice to the organization registration email used at signup and will make the current legal documents available in English and Lithuanian.
This DPA is governed by the laws of the Republic of Lithuania, unless mandatory law requires otherwise.
Privacy and DPA contact: [email protected]
If the English and Lithuanian versions differ, the Lithuanian version prevails.