Draft — to be reviewed by a lawyer
Your viewers' data stays with you
You run the software on your own servers. Your subscribers' and viewers' data — accounts, devices, viewing history, payments to you — is stored and processed there, under your control. We have no access to it and do not process it.
What we process on your behalf
We act on your behalf only when we build your branded apps. For that, the app builder handles:
- the materials you give us: your brand's names, images and colours, and the apps' identifiers;
- the built apps and their files, until they are removed;
- any personal data you put inside these materials, such as a contact address shown in an app.
Roles
For this data you are the controller and we act as your processor, under the agreement summarised here. The accounts your staff use in the customer portal, our billing and the licence check-ins are not processed on your behalf: for them we are the controller, as our privacy policy describes. The agreement follows Article 28 of the EU General Data Protection Regulation (GDPR) and the rules of Brazil's General Data Protection Law (LGPD) on processors.
Main terms
- Instructions: we process the data only to provide the services and on your documented instructions.
- Confidentiality: the people who process it are bound to confidentiality.
- Security: we apply technical and organisational measures, such as encrypted connections, access limited to those who need it, two-factor sign-in for our staff and an audit log.
- Sub-processors: we use our hosting and storage providers to build and keep your apps, and Resend for the emails about your builds. We tell you before we add or replace one, and you may object.
- Assistance: we help you answer requests from the people concerned and tell you without undue delay about a personal data breach.
- Transfers: where data leaves the EU or Brazil, it does so with the safeguards the law requires.
- End of the contract: we delete or return the data, unless the law requires us to keep it.
- Audits: we give you the information you need to check that these terms are kept.
The full agreement
The full agreement is available on request: write to [email protected].