Data Processing Agreement (Art. 28 GDPR)

The customer using Uisdom is the controller; Uisdom is the processor. This agreement forms part of the Terms & Conditions and applies to every customer who has accepted them.

The clauses are reproduced without changes, except for the choices they themselves allow: Regulation (EU) 2016/679 applies; optional Clause 5 is not adopted; for sub-processors, general written authorisation applies with 30 days' notice (Clause 7.7(a), option 2).

The official text of the clauses is published in the Official Journal of the European Union, L 199 of 7 June 2021: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021D0915. In case of any difference, the official text prevails.

For any request about this agreement: uisdomcontact@gmail.com.

(a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

(b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.

(c) These Clauses apply to the processing of personal data as specified in Annex II.

(d) Annexes I to IV are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b) 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.

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

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.

The parties do not adopt this optional clause.

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.

(a) 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.

(b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

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.

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

(a) 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.

(b) 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.

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) 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 Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. 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.

(d) 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.

(e) 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.

(a) GENERAL WRITTEN AUTHORISATION: The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. 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). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) 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 data 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 Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) 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 secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) 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.

(e) 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.

(a) 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 Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. 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 Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) 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 its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions

(c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), 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 Regulation (EU) 2016/679.

(d) 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.

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 Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) 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);

(b) in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, 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.

(c) in complying, pursuant to Article 34 of Regulation (EU) 2016/679, 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.

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) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) 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.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

(a) Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, 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.

(b) 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 (a) 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 Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;

 (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 Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) 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 7.1 (b), the controller insists on compliance with the instructions.

(d) 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.

Name: the Uisdom customer, identified by the details of their account (name or company name and email address; postal address and billing details, if provided).

Contact person's name, position and contact details: the account holder, at the account's email address; the customer's data protection officer, if appointed.

Signature and accession date: acceptance of the Terms & Conditions, on the date recorded in the account.

Name: Cesare D'Adamo (Uisdom.design), sole proprietorship.

Address: Mühlenstrasse 20, 13187 Berlin, Germany.

Contact person's name, position and contact details: Cesare D'Adamo, owner, uisdomcontact@gmail.com. No data protection officer is appointed, as the conditions of Article 37 of Regulation (EU) 2016/679 are not met.

Signature and accession date: publication of this agreement, 5 November 2026.

Visitors of the websites and blogs the customer publishes with Uisdom, in particular those who submit a form.

Persons whose data appears in the content the customer provides, or that Uisdom takes, on the customer's instructions, from their existing website (for example staff, or clients quoted in reviews).

Data entered in the forms the customer publishes, according to the fields the customer chooses: for example name, email, phone, message and any other data the form asks for.

Files uploaded with the forms, for example photos or documents.

Technical visit data in the server logs: IP address, browser type, requested page, date and time.

Personal data contained in the text and images of the customer's websites, blogs and posts.

The service is not designed to process special categories of data (Article 9 of Regulation (EU) 2016/679) or data relating to criminal convictions and offences (Article 10). If the customer collects such data with their own forms, for example in a free-text field or an uploaded document, the safeguards of Annex III apply: access limited to the customer's account and to persons authorised by Uisdom for support, files without a public address, no data in notification emails, deletion at the customer's request.

Hosting and publishing the customer's websites and blogs.

Receiving, storing and showing in the customer's dashboard the submissions sent through forms and their attached files.

Notifying the customer of a new submission with an email that contains no visitor data; sending the submission to the integration address (webhook) the customer configures, if they configure one.

Generating and editing the content of websites, blogs and posts with artificial intelligence systems, based on content provided by the customer or read from their existing website; publishing posts on the social accounts the customer connects, in the plans that include it.

Deleting the data.

Providing the customer with the service described in the Terms & Conditions. Uisdom does not process this data for its own purposes and does not use it to train artificial intelligence models.

For the duration of the contractual relationship with the customer.

Submissions and their files are kept until the customer deletes them from the dashboard or until the account is closed. Technical server logs are deleted or overwritten within 14 days.

When the relationship ends, Uisdom deletes the personal data within 30 days, unless Union or Member State law requires storage. Database backup copies are kept for 7 days, so deleted data also leaves the backups within that period. Attached files are not included in database backups.

This agreement does not cover: third-party services the customer adds to their websites and has a direct relationship with (for example analytics, advertising, chat, booking or privacy-notice tools), for which Uisdom only inserts the code on the customer's instructions; the customer's account and billing data, which Uisdom processes as controller under its own privacy policy.

The subject matter, nature and duration of the processing entrusted to sub-processors are set out in Annex IV.

Form submissions, attached files and website content are stored in the European Union (Ireland). Form submissions are processed in the European Union (Germany).

Communications with the service, and between the service and its providers, use encrypted connections (HTTPS/TLS). Stored data is encrypted at rest by the storage provider.

Each customer's data is accessible only from their account, after authentication, and every operation checks that the account is the one the data belongs to.

Files uploaded with forms have no public address: they open only through temporary links, generated after the customer has authenticated.

Administrative access to the systems is reserved to persons authorised by Uisdom and is used only for support, maintenance and security. Credentials to the systems are kept separately from the service's code.

The emails notifying the customer of a new submission contain no visitor data: only the website name, the number of files received and a link to the dashboard.

Persons authorised by Uisdom to access personal data are bound by confidentiality.

The service relies on infrastructure providers with recognised security certifications; the main ones, Vercel and Supabase, hold SOC 2 Type II certification. The database is backed up every day and each backup copy is kept for 7 days.

Technical server logs are used for security and troubleshooting and are deleted or overwritten within 14 days.

The customer can delete each individual submission from the dashboard; its attached files are deleted with it. When the account is closed, the data is deleted within 30 days.

Uisdom notifies the customer of a personal data breach concerning them without undue delay and in any event within 48 hours of becoming aware of it, at the account's email address, with the information set out in Clause 9.2.

The customer can view and delete the submissions received directly from the dashboard. For data subject requests and any other assistance under Clauses 8 and 9, Uisdom answers written requests sent to uisdomcontact@gmail.com within 10 working days.

Before acting on a request, Uisdom verifies the identity of the person making it: it only accepts requests sent from the email address of the customer's account or confirmed from the dashboard after sign-in, and it never sends data received through forms by email.

Uisdom selects sub-processors on the basis of the guarantees they offer and concludes a data processing agreement with each of them. Transfers to third countries are based on standard contractual clauses or on the EU-U.S. Data Privacy Framework.

Uisdom reviews these measures at least once a year and whenever the service changes significantly.

The controller authorises the use of the following sub-processors (Clause 7.7(a), option 2).

Processing: publishing websites and blogs, receiving and processing form submissions. Data: technical visit data, content of submissions while they are processed.

Location: submissions processed in the European Union (Germany); global delivery network. Safeguards: data processing agreement and standard contractual clauses.

Processing: database and storage of submissions, attached files and website content.

Location: European Union (Ireland). Safeguards: data processing agreement and standard contractual clauses.

Processing: background tasks, such as publishing websites and resending failed notifications, for which it reads the submission.

Location: United States. Safeguards: standard contractual clauses.

Processing: isolated, temporary environments in which websites are built and edited. Data: website content.

Location: United States. Safeguards: standard contractual clauses.

Processing: generating and editing the content of websites, blogs and posts with artificial intelligence. Data: website content and the customer's instructions, excluded from model training.

Location: United States. Safeguards: commercial terms including a data processing agreement and standard contractual clauses.

Processing: reading the customer's existing website, at the customer's request. Data: the public content of that website.

Location: United States. Safeguards: standard contractual clauses.

Processing: only in plans with social publishing, publishing posts on the social accounts the customer connects.

Location: European Union (Spain), with its own sub-processors in the European Union, the United Kingdom and the United States. Safeguards: data processing agreement; standard contractual clauses or adequacy decisions for transfers outside the European Economic Area.