Data Processing Agreement

Last updated: June 2025

1. Subject Matter

This Data Processing Agreement (DPA) governs the processing of personal data carried out by e smartchoice as processor on behalf of the client (controller), in accordance with Regulation (EU) 2016/679 (GDPR).

2. Categories of Data

The data that may be processed includes: names, email addresses, phone numbers, professional information and technical usage data (logs, cookies).

3. Purpose of Processing

Processing is carried out exclusively for the provision of the agreed services, including support, technical maintenance and the improvement of the solutions provided.

4. Processor Obligations

e smartchoice undertakes to process data only on documented instructions, to ensure confidentiality, to take appropriate technical and organizational security measures, and not to transfer data to third countries without a lawful basis.

5. Sub-processors

e smartchoice may use approved sub-processors to provide the services (e.g. cloud hosting services). The client will be informed of any relevant change.

6. Data Subject Rights

e smartchoice assists the controller in fulfilling its obligations towards data subjects, including the rights of access, rectification, erasure and portability.

7. Data Breaches

In the event of a data breach, e smartchoice will notify the controller without undue delay and within 72 hours of becoming aware of the breach.