Data Processing Agreement

Last updated 11 July 2026
This Data Processing Agreement (“Agreement”) forms part of the Contract for Services under the DocEvent.io Terms of Service (the “Principal Agreement”). This Agreement is an amendment to the Principal Agreement and is effective upon its incorporation to the Principal Agreement, which incorporation may be specified in the Principal Agreement or an executed amendment to the Principal Agreement. Upon its incorporation into the Principal Agreement, this Agreement will form a part of the Principal Agreement.
We periodically update this Agreement.
The term of this Agreement shall follow the term of the Principal Agreement. Terms not defined herein shall have the meaning as set forth in the Principal Agreement.
WHEREAS
  • (A) You personally or your company act as a Data Controller (the “Controller”).
  • (B) Your company wishes to subcontract certain Services (as defined below), which imply the processing of personal data, to DocEvent.io, acting as a Data Processor (the “Processor”).
  • (C) The Parties seek to implement a data processing agreement that complies with the requirements of the current legal framework in relation to data processing and with the 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).
  • (D) The Parties wish to lay down their rights and obligations.
IT IS AGREED AS FOLLOWS:

1. Definitions and Interpretation

1.1 Unless otherwise defined herein, capitalized terms and expressions used in this DPA shall have the following meaning:
  • 1.1.1 “Company Personal Data” means any Personal Data Processed by a Contracted Processor on Controller’s behalf pursuant to or in connection with the Principal Agreement;
  • 1.1.2 “Contracted Processor” means a Subprocessor;
  • 1.1.3 “Data Protection Laws” means EU Data Protection Laws and, to the extent applicable, the data protection or privacy laws of any other country;
  • 1.1.4 “EEA” means the European Economic Area;
  • 1.1.5 “EU Data Protection Laws” means EU Directive 95/46/EC, as transposed into domestic legislation of each Member State and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR;
  • 1.1.6 “GDPR” means EU General Data Protection Regulation 2016/679;
  • 1.1.7 “Data Transfer” means:
    • 1.1.7.1 a transfer of Company Personal Data from Controller to a Contracted Processor; or
    • 1.1.7.2 an onward transfer of Company Personal Data from a Contracted Processor to a Subcontracted Processor, or between two establishments of a Contracted Processor, in each case, where such transfer would be prohibited by Data Protection Laws (or by the terms of data transfer agreements put in place to address the data transfer restrictions of Data Protection Laws);
  • 1.1.8 “Services” means end-to-end encrypted data transfer services. The Service is described more in detail in Schedule 1.
  • 1.1.9 “Subprocessor” means any person appointed by or on behalf of Processor to process Personal Data on behalf of Controller in connection with the Agreement.
1.2 The terms, “Commission”, “Controller”, “Data Subject”, “Member State”, “Personal Data”, “Personal Data Breach”, “Processing” and “Supervisory Authority” shall have the same meaning as in the GDPR, and their cognate terms shall be construed accordingly.

2. Processing of Company Personal Data

2.1 Processor shall:
  • 2.1.1 comply with all applicable Data Protection Laws in the Processing of Company Personal Data; and
  • 2.1.2 not process Company Personal Data other than on Controller’s documented instructions.
2.2 Controller instructs Processor to process Company Personal Data to provide the Services and related technical support.

3. Processor Personnel

Processor shall take reasonable steps to ensure the reliability of any employee, agent or contractor of any Contracted Processor who may have access to Company Personal Data, ensuring in each case that access is strictly limited to those individuals who need to know / access the relevant Company Personal Data, as strictly necessary for the purposes of the Principal Agreement, and to comply with Applicable Laws in the context of that individual’s duties to the Contracted Processor, ensuring that all such individuals are subject to confidentiality undertakings or professional or statutory obligations of confidentiality.

4. Security

4.1 Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Processor shall in relation to the Company Personal Data implement appropriate technical and organizational measures to ensure a level of security appropriate to that risk, including, as appropriate, the measures referred to in Article 32(1) of the GDPR.
4.2 In assessing the appropriate level of security, Processor shall take account in particular of the risks that are presented by Processing, in particular from a Personal Data Breach.

5. Subprocessing

5.1 Controller provides a general authorization for Processor to engage Subprocessors to Process Company Personal Data in order to provide the Services. Processor uses the third-party service providers identified in its Privacy Policy as Subprocessors (including cloud infrastructure and hosting providers, payment providers, analytics providers and support providers).
5.2 Processor will impose data-protection obligations on each Subprocessor that are no less protective than those set out in this Agreement, and Processor remains fully liable to Controller for the performance of each Subprocessor’s obligations. Processor will inform Controller of any intended addition or replacement of a Subprocessor by updating the list of Subprocessors in its Privacy Policy, thereby giving Controller the opportunity to object to such change on reasonable data-protection grounds.

6. Data Subject Rights

6.1 Taking into account the nature of the Processing, Processor shall assist Controller by implementing appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of Controller obligations, as reasonably understood by Controller, to respond to requests to exercise Data Subject rights under the Data Protection Laws.
6.2 Processor shall:
  • 6.2.1 promptly notify Controller if it receives a request from a Data Subject under any Data Protection Law in respect of Company Personal Data; and
  • 6.2.2 ensure that it does not respond to that request except on the documented instructions of Controller or as required by Applicable Laws to which the Processor is subject, in which case Processor shall to the extent permitted by Applicable Laws inform Controller of that legal requirement before the Contracted Processor responds to the request.

7. Personal Data Breach

7.1 Processor shall notify Controller without undue delay upon Processor becoming aware of a Personal Data Breach affecting Company Personal Data, providing Controller with sufficient information to allow Controller to meet any obligations to report or inform Data Subjects of the Personal Data Breach under the Data Protection Laws.
7.2 Processor shall co-operate with Controller and take reasonable commercial steps as are directed by Controller to assist in the investigation, mitigation and remediation of each such Personal Data Breach.
7.3 Processor shall indemnify, defend, and hold harmless Controller (and its affiliates, officers, directors, agents and employees) from and against any and all claims, costs, damages, losses, liabilities and expenses (including reasonable attorneys’ fees and costs) resulting from any third-party claim or action arising from or related to a Personal Data Breach affecting Company Personal Data.

8. Data Protection Impact Assessment and Prior Consultation

8.1 Processor shall provide reasonable assistance to Controller with any data protection impact assessments, and prior consultations with Supervising Authorities or other competent data privacy authorities, which Controller reasonably considers to be required by article 35 or 36 of the GDPR or equivalent provisions of any other Data Protection Law, in each case solely in relation to Processing of Company Personal Data by, and taking into account the nature of the Processing and information available to, the Contracted Processors.

9. Deletion or return of Company Personal Data

9.1 Subject to this section 9 Processor shall promptly and in any event within 10 business days of the date of cessation of any Services involving the Processing of Company Personal Data (the “Cessation Date”), delete and procure the deletion of all copies of those Company Personal Data.
9.2 Processor shall provide written certification to Controller that it has fully complied with this section 9 within 10 business days of the Cessation Date.

10. Audit rights

10.1 Subject to this section 10, Processor shall make available to Controller on request all information necessary to demonstrate compliance with this Agreement, and shall allow for and contribute to audits, including inspections, by Controller or an auditor mandated by Controller in relation to the Processing of the Company Personal Data by the Contracted Processors.
10.2 Information and audit rights of Controller only arise under section 10.1 to the extent that the Agreement does not otherwise give them information and audit rights meeting the relevant requirements of Data Protection Law.

11. Data Transfer

11.1 Processor hosts Company Personal Data in the data centre region selected by Controller, and offers regions within the European Economic Area (EEA). Where Company Personal Data is transferred from within the EEA to a country outside the EEA, Processor will ensure that the transfer is subject to appropriate safeguards and that the personal data remains adequately protected in accordance with applicable Data Protection Laws.

12. General Terms

12.1 Confidentiality. Each Party must keep any information it receives about the other Party and its business in connection with this Agreement (“Confidential Information”) confidential and must not use or disclose that Confidential Information without the prior written consent of the other Party except to the extent that:
  • (a) disclosure is required by law;
  • (b) the relevant information is already in the public domain.
12.2 Notices. All notices and communications given under this Agreement must be in writing and will be sent by email. Controller shall be notified by email sent to the address related to its use of the Service under the Principal Agreement. Processor shall be notified by email sent to the address: support@docevent.io

13. Governing Law and Jurisdiction

13.1 This Agreement is governed by and construed in accordance with the laws of the State of New South Wales, Australia, consistent with the Principal Agreement.
13.2 Any dispute arising in connection with this Agreement, which the Parties are unable to resolve amicably, will be submitted to the exclusive jurisdiction of the courts of Sydney, New South Wales, Australia.

Schedule 1: Service Description

The Service offered by DocEvent.io is DocEvent (“DocEvent”). DocEvent provides B2B data transfer services with an easy-to-use interface that connects endpoint protocols such as FTP, FTPS and SFTP to blob and file storage systems in the cloud, such as Amazon S3, Azure Blob Storage, Google Cloud Storage and S3-compatible storage. DocEvent comprises two principal services, which handle Company Personal Data differently:

Simple FTP Service (SFS)

The Simple FTP Service streams data directly between the Controller’s protocol client (FTP/FTPS/SFTP) and the Controller’s own cloud storage bucket. File contents are transferred in a streaming fashion and are not written to disk on, or retained by, DocEvent-controlled servers. Data is encrypted in transit, and DocEvent does not retain the contents of transferred files. Only transfer metadata (such as filename, file size, date and time, and operation type) is logged, for the purposes of usability, billing and logging.

Channels

The Channels service routes and delivers files between parties. To perform this routing and delivery, file contents may be stored transiently in an encrypted, DocEvent-managed cloud storage bucket (Amazon S3 with server-side encryption) for the duration of the transfer and routing process, after which they are deleted in accordance with the applicable retention lifecycle. As with SFS, data is encrypted in transit and only transfer metadata is retained for usability, billing and logging.

Schedule 2: Data Processing and Security

1. Description of the data processing carried out on behalf of the Controller
In addition to the information provided elsewhere in the Agreement, the Parties wish to document the following information in relation to the data processing activities.
The data processing performed by the Data Processor on behalf of the Controller relates to the service of end-to-end data transfer. The data processing details and procedure can be found in the Company’s Privacy Policy document listed on the main website.
For any questions contact support@docevent.io