Data processing agreement

1. Parties and application

This agreement governs personal data that Glenn Chiu trading as Dot Square, a Dutch sole proprietor operating Luximio, processes on the Customer’s documented instructions. Dot Square is the processor; the Customer identified in the acceptance record is the controller. If the Customer is itself a processor, the parties must document the relevant controller’s authority and appropriate processing chain before that use.

Dot Square: KvK 51738856; Kon. Wilhelminaplein 248, 1062 KS Amsterdam, The Netherlands. Contact Glenn Chiu at legal [at] luximio.com or +31 6 39860349. Replace [at] with @ and remove spaces. This is an operational privacy contact, not a claim that a data protection officer has been appointed.

The agreement becomes binding when both parties accept this version with the Customer identity, authorised contacts and covered services/workspaces recorded. Merely visiting this page or accepting a previous sandbox preview does not execute it. Each party keeps a saveable copy and the acceptance record. The agreement lasts for the relevant processing, including required return/deletion handling.

Dot Square’s own account administration, billing, service security and ordinary enquiries have separate controller purposes described in the privacy notice. Classify each operation by its actual purpose; an entire record is not automatically outside this agreement because it also serves an administrative purpose.

2. Processing covered

Service and operations: receiving, storing, updating, publishing and resolving configured deep links; serving web fallbacks and app-association information; checking link health; recording and reporting link events; customer-directed team collaboration; and necessary customer assistance. Processing continues while the Customer uses or instructs the relevant service and during return/deletion handling.

People and data: Customer personnel, invited members, app users and link visitors; contact/name/role information used for collaboration; workspace/project/link and activity identifiers; public destinations, routing/configuration and optional payloads; request/network information; event time, platform, country, referrer origin and app-open/verification results. When enabled, app verification can involve installation/key identifiers, public keys and challenges. Not every field is populated in every operation.

Customers must not put credentials, payment-card details, special-category data, criminal-offence records or health information in public links, payloads or support examples under this standard arrangement. A different sensitive-data use needs a separate assessment and written arrangement. The application does not automatically detect every prohibited submission.

Publication instructs delivery of the published fields to the public. Customer-selected destinations, app stores, association hosts and invitation recipients can receive data through the requested activity; they are not automatically suppliers appointed by Dot Square. Avoid personal information and secrets in URLs because destination servers may log them.

3. Instructions and confidentiality

Documented instructions consist of this agreement, authorised workspace actions and subsequent verified written instructions. Dot Square processes the data only for these instructions and purposes, including for international transfers, unless Union or Member State law requires otherwise. In that case it informs the Customer before processing unless the law prohibits notice on important public-interest grounds.

Dot Square promptly informs the Customer if an instruction appears to infringe applicable data-protection law and seeks clarification. It limits access to people who need it for the service and ensures they are bound by confidentiality or an appropriate statutory duty. Customer data is not used for advertising or model training as part of the instructed service. Development conversations are a separate workflow; unnecessary customer records must not be copied into them.

4. Security measures

Dot Square implements technical and organisational measures appropriate to the risks, taking account of the state of the art, implementation costs, processing and people affected, as required by GDPR Article 32. It maintains and reviews these measures as the service and risks change.

• HTTPS delivery, protected service credentials kept outside public assets, and restricted operator access.
• Verified email-code sign-in, hashed five-minute codes, attempt/rate limits, renewable sessions, workspace permissions and a separate platform-admin allowlist. Incoming Sites identity headers are not trusted.
• Server-side input validation, scoped reporting and access checks. Detailed link-event records store referrer origin rather than the whole referrer and omit raw IP/user-agent columns; infrastructure and session records have separate scope.
• Versioned source and deployment controls, application checks, health checks and scheduled monitoring. The migration restore was verified; no guaranteed recovery time or uptime percentage is asserted by that result.
• Daily cleanup of the implemented ephemeral records, restricted manual rights handling, minimised support examples and the return/deletion procedure below.
• Provider-operated physical infrastructure and recovery controls under the applicable provider agreements. Dot Square’s dashboard database has EU jurisdiction; this does not make every service operation EU-only.

These measures do not claim that the whole service has a particular certification. Dot Square supplies relevant evidence and addresses material gaps through the assistance and audit process.

5. Rights and compliance assistance

Taking account of the nature of processing, Dot Square assists the Customer with data-subject requests through appropriate technical and organisational measures. It forwards requests about Customer-controlled data without undue delay and does not answer on the Customer’s behalf without authorisation. It verifies scope and authority proportionately and protects other customers’ information.

Dot Square also assists with security obligations, breach handling, impact assessments and consultation with supervisory authorities, taking account of the nature of processing and information available to it. Assistance includes relevant data-flow, provider, control and incident information and coordination of necessary provider requests.

The operating target is to acknowledge ordinary instructions within two business days, sooner for urgent deadlines. This does not postpone a statutory deadline. The Customer remains responsible for its decisions and responses as controller; Dot Square must communicate material limitations promptly.

6. Personal-data breaches

Dot Square notifies the Customer without undue delay after becoming aware of a personal-data breach affecting the covered data. It gives the available nature/scope, affected data and people, likely consequences, measures taken or proposed and a contact for follow-up. It supplements information as it becomes available and assists with required notifications and mitigation.

Notification does not wait for a finished investigation or a 72-hour period. Glenn Chiu leads incident handling and monitors requests, arranging cover before planned absences. No separate 24/7 staffing or fixed incident-response service level is promised.

7. Processing suppliers

The Customer gives general written authorisation for the suppliers and purposes in the attached versioned schedule in section 11. Dot Square engages a subprocessor through a contract imposing, in substance, the same applicable data-protection obligations for that processing, including appropriate security guarantees. It remains responsible to the Customer for the performance of its subprocessor obligations.

Dot Square specifically informs affected customers in writing of an intended addition or replacement at least 14 calendar days before that supplier processes their data, providing the identity, work, locations, safeguards and intended date. It allows meaningful assessment, with longer notice where needed. Customers are asked to raise concerns within five calendar days to allow upstream escalation; this does not waive later reasonable objections received before processing begins.

Dot Square checks relevant supplier notices daily and informs affected customers within two calendar days. It works to resolve an objection; if unresolved, it stops the affected processing or arranges termination and return/deletion before the new supplier receives the affected data. A changing website list alone is not the required written notice. No promise is made that a supplier must provide an alternative service it has not agreed to.

8. International processing

Dot Square transfers covered data outside the EEA only on documented instructions and with an applicable GDPR Chapter V mechanism. The Customer authorises the service-specific processing described in section 11, subject to those safeguards; this is not permission for arbitrary onward transfers.

Applicable provider terms provide for recognised adequacy mechanisms where the recipient and processing qualify, or the European Commission’s international-transfer clauses with required assessments and supplementary measures. Dot Square records the relevant recipient, operation and mechanism and provides information on request. A general list of global locations does not establish that every Customer’s data visits each location.

9. Return and deletion

At the Customer’s choice, after the relevant services end Dot Square returns or deletes the covered personal data and deletes existing copies unless Union or Member State law requires storage. It also acts on valid documented instructions during the service. Necessary confidentiality, security and processing obligations continue while data remains.

The approved target is to complete active-system return/deletion within 30 calendar days of the verified instruction or termination creating the duty, subject to an earlier legal or agreed deadline. This is a manual process; the dashboard account preview is not an automated deletion tool. Dot Square distinguishes completed actions, justified legal retention and provider recovery-copy handling and does not certify erasure it cannot substantiate.

Current product recovery periods are documented as 30 days for Paid Cloudflare D1 and 14 days for One.com Basic Mail backups. Cloudflare Workers Logs has a seven-day Paid window. Those periods do not establish a universal maximum for every provider copy. Dot Square seeks appropriate provider deletion/expiry handling, restricts remaining data to the necessary purpose, follows up unresolved copies and reapplies approved erasures after restoration before ordinary use resumes.

Return uses an authenticated, encrypted channel and an agreed machine-readable format. Temporary delivery copies are removed seven days after confirmed receipt, sooner on request where possible. Dot Square keeps only necessary completion evidence. Closing one member’s account does not authorise destruction of another member’s data or a continuing shared workspace; separate required actions and exceptions are explained rather than used as a blanket refusal.

10. Accountability and agreement priority

Dot Square makes available the information necessary to demonstrate compliance with this agreement and GDPR Article 28 and allows and contributes to audits, including inspections, by the Customer or its mandated auditor. Reasonable arrangements protect other customers’ data, secrets and security without preventing necessary or urgent audit rights. Provider evidence can support an assessment but does not automatically replace those rights.

Each party keeps appropriate records and cooperates with competent supervisory authorities. For covered processing, this agreement prevails over conflicting general service terms. Mandatory rights, responsibilities and liability under applicable law remain unaffected. Dutch law applies subject to mandatory protections and jurisdiction rules; this document does not impose an exclusive forum on consumers.

This is an independently drafted Article 28 agreement. It is not the European Commission’s standard contractual clauses and does not claim that a supplier has granted an unsupported customer right to take over its contract.

11. Agreed supplier schedule

The version 2026-09-26 provider schedule gives the published downstream context and separate recipient roles. Attach that exact schedule to the accepted copy; a later webpage update does not silently amend it. Ordinary billing through Stripe, Dot Square’s own account purposes, customer-selected destinations and native app-platform operations require their separate role analysis rather than being automatically added to this customer-link subprocessor list.

OpenAI Sites is not a supplier for the current dashboard. The retired dashboard’s historical copies and separate private previews are recorded in the privacy notice; they do not authorise new Customer data to be sent there.

12. Customer details and acceptance

Complete and retain this record with the full agreement and supplier schedule before relying on it for a customer’s processing. The parties may sign or use a documented electronic acceptance that identifies the authorised people and exact versions. General website publication is not acceptance.

Customer legal name and address

Complete for the contracting controller.

Customer contact and authority

Name, position, monitored privacy/incident contact and authority to accept.

Covered service

Order/reference and workspace/project identifiers; record any agreed variation in processing.

Customer acceptance

Authorised name, signature or electronic acceptance record, and date.

Dot Square acceptance

Glenn Chiu, sole proprietor; signature or electronic acceptance record, and date.

Versions attached

Data processing agreement 2026-09-26 and provider schedule 2026-09-26.