Data Processing Agreement (DPA)
pursuant to Art. 28 GDPR
Personalrampe Digital
between
[Customer Company Name]
[Customer Address]
(hereinafter "Controller")
and
Luis Moretto, operating as "Personalrampe Digital"
An der Windecke 9, 58300 Wetter
Email: privacy@personalrampe.de
(hereinafter "Processor")
§ 0 Language
The Data Processing Agreement is available in German and English. In case of discrepancies or disputes regarding interpretation, the German version shall prevail.
§ 1 Subject Matter and Duration
- Subject matter: The Processor processes personal data on behalf of the Controller for the purpose of providing the services under the main contract.
- Duration: This DPA commences upon conclusion of the main contract and ends upon its termination.
§ 2 Nature and Purpose of Processing
Purpose of processing:
- Digitisation of personnel files (upload, OCR, text extraction),
- Structuring of extracted content,
- AI-supported generation of summaries and insights,
- Provision of an AI assistant for HR queries,
- Operation of the Platform.
§ 3 Categories of Data Subjects
- Employees of the Controller,
- Former employees of the Controller,
- HR administrators and personnel managers of the Controller as Platform users,
- Other users authorised by the Controller.
§ 4 Categories of Personal Data
- Master and contact data,
- Employment and contract data,
- Remuneration and benefits data,
- Performance and behaviour data,
- Attendance and absence data,
- System and usage data,
- Audit log data,
- Special categories of personal data (Art. 9 GDPR) if contained in documents.
§ 5 Obligations of the Processor
The Processor undertakes:
- to process personal data only on documented instructions of the Controller,
- to ensure confidentiality,
- to implement technical and organisational measures (Annex 1),
- to comply with sub-processor obligations,
- to assist the Controller with data subjects' rights and obligations under Art. 32-36 GDPR,
- to return or delete data upon termination,
- to demonstrate compliance through audits.
§ 6 Sub-Processors
The following sub-processors are approved: Vercel Inc. (EU Hosting), Supabase Inc. (EU Database), Mailgun (EU Email). For billing data only (no employee data): Dodo Payments Limited, 3rd Floor Crown House, 151 High Road, Loughton IG10 4LG, United Kingdom, VAT: 495 1783 48.
§ 7-11 Misc.
(Sections 7-11 remain valid as per standard DPA terms).
Annex 1: Technical and Organisational Measures (TOMs)
(As per standard TOMs).