Data processing agreement

1. Purpose
This Data Processing Agreement applies where the client acts as controller and Newdigisol Media SRL processes personal data as processor through hosting, email, software or managed services.

2. Processing instructions
We process personal data only on documented client instructions, including service configuration, support requests and legal obligations applicable to the provider.

3. Categories of data
Hosted data may include website data, email data, account users, logs, database content and any personal data uploaded by the client.

4. Confidentiality and security
Personnel and authorised contractors with access to personal data are bound by confidentiality obligations. We apply reasonable technical and organisational security measures appropriate to the service.

5. Sub-processors
The client authorises use of sub-processors required for hosting infrastructure, data centres, domain services, email delivery, payment processing and support tools. Maintain an updated list of actual sub-processors before launch.

6. Assistance
We assist the client, within reasonable limits, with data subject requests, security incidents, DPIA support and compliance obligations related to the provided services.

7. Data breach notice
We notify the client without undue delay after becoming aware of a personal data breach affecting client-controlled data.

8. Deletion or return
After service termination, data is deleted or returned according to backup cycles, technical limits and legal retention obligations.

9. Audit
Audit requests must be reasonable, documented and limited to information necessary to demonstrate compliance, without compromising other clients or platform security.