Data Processing Agreement
Data Processing Agreement for DataMCP
Data Processing Agreement (DPA)
Last updated: January 1, 2024
This Data Processing Agreement (“DPA”) forms part of the Terms of Service between DataMCP (“Processor”) and you (“Controller”) regarding the processing of personal data.
1. Definitions
- Controller: The entity that determines the purposes and means of processing personal data
- Processor: DataMCP, which processes personal data on behalf of the Controller
- Personal Data: Any information relating to an identified or identifiable natural person
- Processing: Any operation performed on personal data
- Data Subject: The individual whose personal data is being processed
2. Scope and Application
This DPA applies when:
- You use DataMCP services in a business context
- Personal data is processed as part of our service delivery
- You act as a Controller under applicable data protection laws
- GDPR, CCPA, or similar regulations apply
3. Data Processing Details
Categories of Data Subjects
- Your employees and team members
- End users of your applications
- Database administrators and developers
Categories of Personal Data
- Contact information (names, email addresses)
- Account credentials and authentication data
- Usage data and service interactions
- Database metadata (excluding actual data content)
Processing Purposes
- Providing database schema extraction services
- User authentication and access control
- Service monitoring and optimization
- Customer support and communication
- Billing and payment processing
4. Processor Obligations
DataMCP commits to:
- Process personal data only as instructed by you
- Implement appropriate technical and organizational measures
- Ensure confidentiality of personal data
- Assist with data subject rights requests
- Notify you of any data breaches
- Delete or return data upon termination
5. Technical and Organizational Measures
Security Measures
- AES-256-GCM encryption for data at rest
- TLS 1.3 encryption for data in transit
- Multi-factor authentication for admin access
- Regular security audits and penetration testing
- SOC 2 Type II compliance (in progress)
Access Controls
- Role-based access permissions
- Principle of least privilege
- Regular access reviews
- Secure authentication mechanisms
Data Minimization
- Collect only necessary personal data
- Automated data retention policies
- Regular data purging procedures
- Privacy-by-design architecture
6. Sub-processors
We may engage sub-processors to assist in service delivery:
Current Sub-processors
- Clerk: Authentication services
- Vercel: Hosting and infrastructure
- Stripe/Paddle: Payment processing
- Resend: Email delivery services
Sub-processor Requirements
- Equivalent data protection obligations
- Written agreements with security requirements
- Regular compliance monitoring
- Right to audit and inspect
7. Data Subject Rights
We will assist you in responding to:
- Access requests
- Rectification requests
- Erasure requests
- Portability requests
- Objection to processing
- Restriction of processing
8. Data Transfers
International Transfers
- Data may be processed in the United States
- Adequate safeguards implemented
- Standard Contractual Clauses where applicable
- Regular adequacy decision monitoring
Transfer Mechanisms
- EU-US Data Privacy Framework participation (pending)
- Standard Contractual Clauses (SCCs)
- Binding Corporate Rules where applicable
9. Data Breach Notification
In case of a personal data breach:
- Notification to you within 72 hours of discovery
- Detailed incident report provided
- Assistance with regulatory notifications
- Remediation measures implemented
10. Audits and Compliance
Audit Rights
- Annual compliance reports provided
- Right to conduct audits (with reasonable notice)
- Third-party audit reports available
- Compliance documentation maintained
Compliance Monitoring
- Regular internal audits
- External security assessments
- Continuous monitoring systems
- Incident response procedures
11. Data Retention and Deletion
Retention Periods
- Account data: Duration of service agreement
- Usage logs: 12 months maximum
- Backup data: 90 days maximum
- Billing records: As required by law
Deletion Procedures
- Secure deletion within 30 days of termination
- Certification of deletion provided
- Backup data included in deletion
- Recovery impossible after deletion
12. Liability and Indemnification
- Liability limited to direct damages
- Indemnification for processor breaches
- Insurance coverage maintained
- Limitation of liability applies
13. Term and Termination
This DPA:
- Remains in effect during service provision
- Survives termination for data deletion obligations
- May be updated with 30 days notice
- Terminates upon complete data deletion
14. Governing Law
This DPA is governed by:
- Laws of the jurisdiction specified in Terms of Service
- Applicable data protection regulations
- International data transfer requirements
Contact Information
For DPA-related matters:
- Email: dpo@datamcp.com
- Subject: “Data Processing Agreement”
- Address: [To be added]
Data Protection Officer: [To be appointed]