Data Processing Agreement

Template requiring legal review before use.

Where a customer acts as controller of personal data processed through its Parlo chat, Parlo acts as processor only on documented instructions necessary to provide the service.

Subject matter

Hosting, transmission, storage, moderation tooling, security and backup of chat data for the duration of the service.

Data and data subjects

Chat users, moderators and administrators; usernames, messages, media, moderation records, session/security identifiers, IP addresses and other data submitted through the service.

Processor duties

Confidentiality, appropriate technical and organisational measures, reasonable assistance with data-subject rights and incidents, deletion/return at the end of processing, and information needed to demonstrate compliance.

Subprocessors

Potential subprocessors include OVHcloud, Resend and other infrastructure providers actually enabled. Paddle generally processes billing within its own Merchant of Record relationship. The final subprocessor list and transfer safeguards must be completed before production.