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Data Processing Agreement

Effective date: April 9, 2026

This Data Processing Agreement ("DPA") forms part of the Terms of Service between automrktr and the subscribing business entity ("Customer"). By using the Service, Customer agrees to the terms of this DPA. No separate signature is required — acceptance of the Terms of Service incorporates this DPA.

1. Definitions

In this DPA, the following terms have the meanings given below. Capitalised terms not defined here have the meanings given in the Terms of Service.

  • "Controller" means the natural or legal person who determines the purposes and means of processing Personal Data. Customer is the Controller of Customer Personal Data.
  • "Processor" means a natural or legal person who processes Personal Data on behalf of the Controller. automrktr is the Processor of Customer Personal Data.
  • "Customer Personal Data" means any Personal Data that Customer uploads, submits, or otherwise provides to automrktr through the Service, or that automrktr collects on Customer's behalf (including via the conversion pixel), in connection with Customer's use of the Service.
  • "Data Subject" means an identified or identifiable natural person to whom Customer Personal Data relates.
  • "GDPR" means the EU General Data Protection Regulation (2016/679), the UK GDPR (as defined in the Data Protection Act 2018), and any implementing legislation, as applicable.
  • "Personal Data" has the meaning given under applicable data protection law, including the GDPR.
  • "Processing" has the meaning given under applicable data protection law and "process" and "processed" shall be construed accordingly.
  • "Security Incident" means a confirmed breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Customer Personal Data.
  • "Sub-processor" means any Processor engaged by automrktrto process Customer Personal Data.
  • "Supervisory Authority" means the data protection authority with jurisdiction over Customer or automrktr under applicable law.

2. Roles and Scope

This DPA applies where and to the extent that automrktr processes Customer Personal Data as a Processor on behalf of Customer in connection with the Service.

Customer is the Controller of Customer Personal Data. automrktr is the Processor. Each party shall comply with its obligations as Controller and Processor respectively under applicable data protection law.

This DPA does not apply to Personal Data for which automrktr is independently a Controller (e.g. account registration data, billing data, and platform usage data of Customer's users), which is governed by automrktr's Privacy Policy.

3. Details of Processing

Subject Matter

automrktr's provision of the Service to Customer, including AI content generation, social media scheduling and publishing, ad management, analytics, and conversion tracking.

Duration

For the duration of Customer's subscription, and for up to 30 days thereafter pending deletion, as described in Section 9 of this DPA.

Nature and Purpose of Processing

  • Storing and processing content uploaded by Customer for scheduling and publication to connected social media platforms.
  • Publishing content to social media platforms on Customer's behalf.
  • Collecting and processing conversion and analytics data from Customer's website via the tracking pixel.
  • Storing and using social media platform access tokens to perform authorised actions.
  • Providing performance analytics and reporting to Customer.

Categories of Personal Data

  • Social media account identifiers and public profile data of accounts managed by Customer.
  • Content (text, images, video) uploaded by Customer that may reference or depict individuals.
  • Website visitor data collected via the conversion pixel: IP addresses, device identifiers, page URLs, and behavioural events.
  • Audience and engagement data received from connected social media platforms.

Categories of Data Subjects

  • Followers and audiences of Customer's social media accounts.
  • Visitors to Customer's website (where the pixel is installed).
  • Individuals depicted in or referenced by Customer's content.
  • Customer's own clients and end users (for agency subscribers).

4. Processor Obligations

Processing on Instructions Only

automrktr shall process Customer Personal Data only on Customer's documented instructions, as set out in this DPA and the Terms of Service, unless required to do so by applicable law, in which case automrktr shall notify Customer before such processing unless prohibited from doing so by law.

Confidentiality

automrktr shall ensure that personnel authorised to process Customer Personal Data are subject to appropriate confidentiality obligations and have received adequate data protection training. Access to Customer Personal Data is limited to personnel who require it to perform the Service.

Compliance with Law

automrktr shall promptly notify Customer if, in automrktr's reasonable opinion, an instruction from Customer infringes applicable data protection law. automrktr shall not be required to perform any instruction that it reasonably believes would cause either party to violate applicable law.

5. Security Measures

Taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing, automrktr implements and maintains appropriate technical and organisational measures to protect Customer Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access, including:

  • Encryption of Customer Personal Data at rest (AES-256-GCM) and in transit (TLS 1.2+).
  • Role-based access controls limiting access to authorised personnel only.
  • Audit logging of access to Customer Personal Data.
  • Regular security monitoring and vulnerability management.
  • Contractual security obligations imposed on all Sub-processors.
  • Procedures for testing, assessing, and evaluating the effectiveness of security measures.

automrktr may update security measures over time provided the overall level of protection is not materially reduced.

6. Sub-processors

Authorisation

Customer provides general authorisation for automrktr to engage Sub-processors, subject to the requirements of this section. automrktr shall impose data protection obligations on all Sub-processors equivalent to those set out in this DPA, by written contract. automrktr remains liable to Customer for the acts and omissions of its Sub-processors to the same extent as if automrktr had performed the processing directly.

Current Sub-processors

Sub-processorPurposeLocation
SupabaseDatabase and authenticationUSA
StripePayment processingUSA
CloudinaryMedia storage and deliveryUSA
ResendTransactional emailUSA
UpstashJob queuing and schedulingUSA
SentryError monitoringUSA
AnthropicAI content generationUSA
ReplicateAI image generationUSA
CloudflareCDN, edge compute, DNSUSA / Global

Changes to Sub-processors

automrktr will provide at least 14 days' prior written notice (by email or in-platform notice) before adding or replacing a Sub-processor. Customer may object to a new Sub-processor on reasonable data protection grounds by emailing privacy@automrktr.io within 14 days of notice. If the parties cannot resolve the objection, Customer may terminate the affected portion of the Service without penalty by providing written notice within 30 days of automrktr's notice.

7. Data Subject Rights

automrktr shall, taking into account the nature of the processing, assist Customer by appropriate technical and organisational measures in fulfilling Customer's obligation to respond to requests from Data Subjects exercising their rights under applicable data protection law (including rights of access, rectification, erasure, restriction, portability, and objection).

If automrktr receives a request directly from a Data Subject relating to Customer Personal Data, automrktr will promptly forward the request to Customer and will not respond to the Data Subject directly except to confirm that the request has been forwarded, unless required by applicable law. Customer is responsible for responding to Data Subject requests within applicable legal timeframes.

8. Security Incident Notification

automrktr shall notify Customer without undue delay, and in any event within 72 hours of becoming aware of a confirmed Security Incident affecting Customer Personal Data. The notification will include, to the extent then known:

  • A description of the nature of the Security Incident, including categories and approximate number of Data Subjects and records affected.
  • The name and contact details of the data protection point of contact.
  • The likely consequences of the Security Incident.
  • The measures taken or proposed to address the Security Incident.

Where not all information is available within 72 hours, automrktr will provide available information and supplement it as further details become known. Notification under this section does not constitute an admission of fault or liability by automrktr.

Customer is solely responsible for determining whether the Security Incident requires notification to Data Subjects or Supervisory Authorities and for making any such notifications. automrktr will reasonably cooperate with Customer in preparing any required notifications.

9. Deletion and Return of Data

Upon expiry or termination of the Terms of Service, automrktr shall, at Customer's election made within 30 days of termination:

  • Return: Provide Customer with an export of Customer Personal Data in a machine-readable format, to the extent technically feasible; or
  • Delete: Securely delete all Customer Personal Data fromautomrktr's systems and those of its Sub-processors.

If Customer does not make an election within 30 days, automrktr will delete all Customer Personal Data. automrktr may retain Customer Personal Data for longer periods where required by applicable law, in which case automrktr will continue to protect it in accordance with this DPA.

10. Audit Rights

automrktr shall make available to Customer all information reasonably necessary to demonstrate compliance with this DPA and shall, upon Customer's written request (no more than once per 12-month period, unless there is a reasonable basis to suspect a Security Incident), allow for and contribute to audits conducted by Customer or an independent auditor appointed by Customer and approved by automrktr (such approval not to be unreasonably withheld).

Customer shall provide at least 30 days' prior written notice of any audit, conduct audits during normal business hours, minimise disruption to automrktr's operations, and bear all costs of the audit. Any third-party auditor must sign a confidentiality agreement acceptable to automrktr before commencing the audit.

In lieu of an on-site audit, automrktr may satisfy this obligation by providing Customer with up-to-date third-party audit reports, certifications, or summaries of its security controls (e.g. SOC 2 reports), where available.

11. International Data Transfers

automrktr is based in the United States. To the extent that automrktr processes Customer Personal Data originating from the EEA, UK, or Switzerland in the United States or another country not recognised as providing adequate data protection, such transfers are made pursuant to the following transfer mechanisms:

  • EU Standard Contractual Clauses (SCCs): The Module Two (Controller to Processor) SCCs adopted by the European Commission on 4 June 2021 are incorporated into this DPA by reference and form part of the agreement between Customer (as data exporter) and automrktr (as data importer).
  • UK International Data Transfer Agreement (IDTA): For transfers from the UK, the UK IDTA (or UK Addendum to the EU SCCs) is incorporated into this DPA by reference.

Where automrktr relies on SCCs or the IDTA for transfers to Sub-processors, it will ensure equivalent protections apply to onward transfers. Copies of the applicable transfer documentation are available upon written request to privacy@automrktr.io.

12. Customer Obligations

Customer represents, warrants, and agrees that:

  • Customer has a lawful basis under applicable data protection law to provide Customer Personal Data to automrktr for processing as described in this DPA.
  • Customer has provided all required notices and obtained all required consents from Data Subjects for the processing described in this DPA.
  • Customer's instructions to automrktr regarding the processing of Customer Personal Data comply with applicable data protection law.
  • Customer is responsible for the accuracy, quality, and legality of Customer Personal Data and the means by which Customer obtained it.
  • Where Customer uses the conversion pixel, Customer has made all disclosures required by applicable law in its own privacy policy and has obtained all necessary consents from website visitors.

13. Data Protection Impact Assessments

Where Customer is required under applicable data protection law (including GDPR Article 35) to conduct a Data Protection Impact Assessment ("DPIA") in connection with processing activities that involve Customer Personal Data processed by automrktr, automrktr shall provide reasonable assistance to Customer in conducting such DPIA, taking into account the nature of the processing and the information available to automrktr. Such assistance may include providing information about automrktr's processing operations, security measures, Sub-processors, and this DPA.

Customer is solely responsible for determining when a DPIA is required, conducting the DPIA, and any prior consultation with a Supervisory Authority that may be necessary under GDPR Article 36. automrktr's assistance under this section does not constitute legal advice and does not guarantee regulatory compliance.

14. Records of Processing Activities

automrktr shall maintain records of all categories of processing activities carried out on behalf of Customer as required by GDPR Article 30(2), including:

  • The name and contact details of automrktr and, where applicable, automrktr's data protection contact.
  • The categories of processing carried out on behalf of Customer.
  • Transfers of Customer Personal Data to third countries and the safeguards in place.
  • A general description of the technical and organisational security measures in place.

automrktr will make such records available to Customer or a Supervisory Authority upon written request, to the extent required by applicable law. Customer is separately responsible for maintaining its own records of processing activities as Controller under GDPR Article 30(1).

15. Liability

Each party's liability to the other under or in connection with this DPA is subject to the limitations and exclusions set out in the Terms of Service. Nothing in this DPA limits either party's liability for its own acts or omissions that constitute a breach of this DPA, to the extent such limitation is not permitted by applicable data protection law.

Where a Data Subject brings a claim against automrktr for damage caused by Customer's processing, Customer shall indemnify automrktr for any such liability to the extent automrktr is held liable for Customer's acts or omissions as Controller.

16. Term and Termination

This DPA takes effect on the date Customer accepts the Terms of Service and remains in force for the duration of the Terms of Service. Termination of the Terms of Service automatically terminates this DPA, subject to Section 9 (Deletion and Return of Data) and any obligations that by their nature survive termination.

17. Governing Law

This DPA is governed by the same law as the Terms of Service (the laws of the State of Utah, United States), except that where mandatory provisions of GDPR or other applicable data protection law apply, those provisions shall prevail to the extent of any conflict.

18. Order of Precedence

In the event of any conflict or inconsistency between this DPA and the Terms of Service with respect to the processing of Personal Data, this DPA shall prevail. In all other respects, the Terms of Service shall prevail.

19. Contact

Questions about this DPA or data protection matters? Contact our privacy team at privacy@automrktr.io.