Data Processing Agreement (DPA / AVV Art. 28 GDPR)

Under Article 28 of the EU General Data Protection Regulation (GDPR), where a controller engages a processor to process personal data on its behalf, the parties must sign a written Data Processing Agreement (DPA / AVV — Accordo sul Trattamento dei Dati Personali) that meets the requirements of Art. 28(3) GDPR.

Lead Machine Contributors maintain a template DPA incorporating the European Commission's Standard Contractual Clauses (Module 2: Controller-to-Processor, Decision 2021/914/EU and subsequent amendments), including the Technical and Organisational Measures (TOMs / Misure Tecniche e Organizzative) Annex. This DPA is primarily relevant to Users who run community or self-hosted custom deployments, or who request a signed DPA for internal compliance reasons. To obtain a signed copy, please email axsen_kurtoski@financier.com with the subject line “DPA Request” and include: — The full legal name, address, VAT ID, and registered email of the Controller; — Description of the processing to be carried out (which services, categories of data subjects, categories of data, duration). We will return a countersigned DPA PDF within 7 working days.