Draft notice: this Data Processing Addendum is a working draft. Replace with lawyer-reviewed text and confirm: sub-processor list current; security measures match V85 work; breach-notification window matches your incident-response capability; SCCs version current.
Data Processing Addendum
Last updated 2026-04-25 · Version 1
This Data Processing Addendum (“DPA”) supplements the Terms of Service between you (“Controller”) and IAVA Productions (“Processor”) and applies whenever Processor processes personal data on behalf of Controller in the course of providing the IAVA one service. This DPA is designed to comply with the EU General Data Protection Regulation (“GDPR”), the UK GDPR, and the Swiss FADP.
To countersign this DPA, email anton@iava.one with your organization name, address, and signatory contact. We will return a counter-signed copy by email.
1. Definitions
- Controller: you, the customer who decides the purposes and means of processing personal data via IAVA one.
- Processor: IAVA Productions, processing personal data on behalf of Controller.
- Personal Data: any information relating to an identified or identifiable natural person processed by Processor on behalf of Controller via the Service.
- Sub-processor: a third party engaged by Processor to assist with processing personal data.
- Data Subject: the individual to whom Personal Data relates (typically Controller's clients, leads, contacts).
- Other terms have the meanings given in the GDPR.
2. Subject matter, duration, nature, and purpose
- Subject matter: provision of the IAVA one customer-relationship-management and project-management Service.
- Duration: for as long as Controller's account is active, plus any post-termination retention period required by law.
- Nature: collection, storage, structuring, retrieval, transmission, deletion, and use in AI features as configured by Controller.
- Purpose: enabling Controller to manage their video-production business — clients, leads, projects, invoices, deliverables, and related communications.
3. Categories of data subjects and personal data
Data subjects: Controller's clients, leads, employees / collaborators, and any other natural persons whose data Controller chooses to enter into the Service.
Categories of personal data (typical):
- Identification data: name, email, phone, company.
- Communication data: email subjects/bodies (when Gmail is connected), calendar events.
- Project data: scope, budget, timeline, deliverables, notes.
- Financial data: invoices, payment status (no card numbers — handled by Stripe).
- AI-derived data: extracted facts, summaries, drafted replies (generated from Controller's own data).
Special-category data: Processor does not require special-category personal data. Controller agrees not to use the Service to process such data without first informing Processor and entering into appropriate additional safeguards.
4. Sub-processors
Processor engages the following sub-processors to provide the Service:
| Sub-processor | Purpose | Location |
|---|---|---|
| Supabase | Database + auth | EU / US |
| Vercel | Application hosting | Global edge |
| Stripe | Payment processing | US / IE |
| OpenRouter | AI API gateway | US |
| Resend | Transactional email | US |
| Gmail / Calendar OAuth | Global | |
| Sentry | Error monitoring | US |
Processor will provide Controller with at least 30 days' advance notice of any new sub-processor or change to this list. Controller may object to such changes by notifying Processor; if the parties cannot resolve the objection, Controller may terminate the affected service.
5. Security measures
Processor implements appropriate technical and organizational measures to protect Personal Data, including:
- TLS 1.2+ for all data in transit.
- AES-256-GCM encryption at rest for OAuth refresh tokens and other secrets.
- Row-level security (RLS) on all customer-scoped database tables; public-token surfaces use a dedicated anon client with token-validated policies.
- HMAC-signed OAuth state parameters to prevent CSRF / state-substitution attacks.
- High-entropy (256-bit) random tokens for public sharing URLs; row primary keys are never used as public tokens.
- Public-form input is wrapped in delimiters before being passed to AI prompts to mitigate prompt injection.
- Rate limiting on public endpoints; audit logging of public-portal access.
- Principle of least privilege for Processor personnel.
- Regular security review of dependencies and infrastructure.
- Backup and disaster-recovery procedures aligned with the underlying database provider (Supabase).
6. Data subject rights
Processor will, taking into account the nature of the processing, assist Controller with appropriate technical and organizational measures to fulfill Controller's obligations to respond to data subjects exercising their rights under GDPR (access, rectification, erasure, restriction, portability, objection). Controller can exercise its admin actions (account deletion, data export) directly via the Service; for additional support, contact anton@iava.one.
7. Personal data breach notification
Processor will notify Controller without undue delay — and in any event within seventy-two (72) hours — after becoming aware of a personal data breach affecting Controller's data. Notification will include the nature of the breach, categories and approximate number of data subjects, likely consequences, and mitigation measures.
8. International data transfers
When Personal Data is transferred outside the European Economic Area, the United Kingdom, or Switzerland, Processor relies on the European Commission's Standard Contractual Clauses (Module Two: Controller-to-Processor, 2021/914) and equivalent safeguards under the UK Addendum and Swiss FADP, incorporated into this DPA by reference.
9. Audit rights
Upon reasonable written request and no more than once per year (except where required by a supervisory authority), Processor will provide Controller with information necessary to demonstrate compliance with this DPA. Processor may satisfy such requests by providing third-party audit reports (e.g., its sub-processors' SOC 2 reports) where available.
10. Term, return, and deletion
This DPA is effective for as long as Processor processes Personal Data on Controller's behalf. Upon termination of the Service, Controller may export its data via the Settings page; Processor will delete Personal Data from active systems within 30 days and from backups within 90 days unless retention is required by law.
11. Governing law
This DPA is governed by the law of the Province of Ontario, Canada, except to the extent the Standard Contractual Clauses are governed by the law of the EU member state where the data exporter is established.
12. Order of precedence
In the event of any conflict between this DPA, the Standard Contractual Clauses, and the Terms of Service, the order of precedence is: (1) Standard Contractual Clauses, (2) this DPA, (3) the Terms of Service.
13. Contact
IAVA Productions, Ontario, Canada
Email: anton@iava.one