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Trust Center DPA

DPA

This English text is a translation provided for convenience. The French version is the only binding one — in case of any discrepancy, the French version prevails.

1 June 2025

DATA PROCESSING AGREEMENT

Between the parties

  • The Client: data controller
  • Saalz (SaaS CRM), operated by SITENCO ("Processor")

Preamble

This agreement is intended to ensure the compliance of the personal data processing carried out by Saalz on behalf of the Client, in accordance with Articles 28.3 and 28.4 of Regulation (EU) 2016/679 (GDPR).

1. PURPOSE OF THE AGREEMENT

This agreement governs the personal data processing carried out by Saalz for the Client in connection with the use of the Saalz CRM platform.

2. DESCRIPTION OF THE PROCESSING

  • Categories of data subjects: the Client's prospects and customers (B2B professionals).
  • Categories of data processed: last name, first name, business email, telephone number, job title, company, public data from LinkedIn and public sources.
  • Nature of the processing: data enrichment, temporary storage, customer relationship management and commercial prospecting.
  • Purposes: to enable the Client to manage its prospecting and customer relationship operations.
  • Data retention period: for the term of the contract and up to 12 months after termination, unless legal obligations provide otherwise.

3. DOCUMENTED INSTRUCTIONS FROM THE CLIENT

Saalz acts exclusively on the Client's documented instructions, unless required to do otherwise by a provision of Union or French law. In that case, Saalz will inform the Client of that obligation, unless prohibited by law.

Saalz will inform the Client if, in its view, an instruction constitutes an infringement of the GDPR or of any other applicable regulation.

4. SECURITY OF THE PROCESSING

Saalz implements appropriate technical and organisational measures to guarantee the confidentiality, integrity, availability and resilience of systems and data (detailed in Annex 1).

Access to data is strictly limited to authorised staff and subject to a confidentiality undertaking.

5. DOCUMENTATION & AUDIT

Saalz makes available to the Client all the information necessary to demonstrate compliance with the obligations set out in this agreement.

Upon reasoned request and where there is serious evidence of non-compliance, the Client may audit the processing carried out, directly or through an independent auditor, with 30 days' notice. Such audits will be carried out during business hours and within reasonable limits of frequency.

Saalz undertakes to cooperate with supervisory authorities upon request.

6. FURTHER SUB-PROCESSING

Saalz has general authorisation to engage sub-processors (see the list of sub-processors, kept up to date).

Saalz will inform the Client of any change at least 8 days before a new sub-processor is added, so that the Client may raise a reasoned objection. Failing an objection within that period, the new sub-processor will be deemed accepted.

Saalz contractually imposes on its sub-processors data protection commitments equivalent to those set out in this DPA.

7. INTERNATIONAL DATA TRANSFERS

Data is hosted within the European Union (Hetzner Cloud, Germany). Certain sub-processors may occasionally process data outside the EU under standard contractual clauses (SCCs) approved by the European Commission.

No transfer outside the EU is carried out without a legal framework compliant with the GDPR (Chapter V).

8. ASSISTANCE TO THE CLIENT

Saalz assists the Client:

  • in handling requests from data subjects to exercise their rights (access, rectification, objection, erasure, restriction, portability);
  • with data protection impact assessments (PIA/DPIA) where the processing requires them;
  • with any prior consultation of the CNIL that may be required.

Requests to exercise rights received directly by Saalz will systematically be forwarded to the Client, unless specifically agreed otherwise.

9. DATA BREACHES

In the event of a personal data breach, Saalz will inform the Client without undue delay after becoming aware of it.

The notification will include in particular:

  • a description of the nature of the breach,
  • the approximate number of data subjects concerned,
  • the likely consequences,
  • the measures taken to remedy the incident.

Where not all the information is immediately available, Saalz will provide the details progressively as they are obtained.

10. FATE OF THE DATA AT THE END OF THE CONTRACT

On expiry of the contract, the Client's data is retained for a period of 12 months to allow for possible reactivation.

After that period, the data is permanently deleted, unless legal obligations provide otherwise. Backups follow the same deferred erasure policy.

11. LIABILITY AND LIMITATION

The Client remains responsible for the lawfulness of the data collected and processed through Saalz. Saalz acts solely as a technical processor.

In the event of serious and repeated failure by either party to comply with the obligations of this agreement, the other party may suspend or terminate the agreement.

12. GOVERNING LAW AND JURISDICTION

This agreement is governed by French law. Any dispute will fall within the exclusive jurisdiction of the courts having jurisdiction over SITENCO's registered office.

ANNEX 1 — TECHNICAL AND ORGANISATIONAL SECURITY MEASURES

  • Data encryption: SSL/TLS encryption of communications, AES encryption of data at rest, Bcrypt hashing of passwords.
  • Partitioned infrastructure: isolated servers on Hetzner cloud (Germany), secure VPC.
  • Access control: strong authentication, RBAC role management, internal access control with traceability.
  • Logging: recording of access and critical actions, logs retained for 12 months.
  • Backups: secure daily backups, limited retention, regular restore testing.
  • Monitoring and intrusion detection: proactive supervision, alerts on suspicious activity.
  • Internal testing and audits: recurring security testing on application updates.
  • Sub-processor compliance: selection of GDPR-compliant providers and reinforced contractual commitments.
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