Data processing agreement (DPA)
Agreement between the shop (the Controller) and RepariDZ (the Processor) for the personal data entered in the service.
Parties, purpose and duration
Controller: the shop holding the account. Processor: RepariDZ, [TO BE COMPLETED] (company name, tax and trade register numbers, address, representative).
The Processor processes personal data on the Controller's behalf to provide the repair management service, for the duration of the service and until the data is purged.
Nature of data and data subjects
- Operations: collection, recording, hosting, consultation, return, erasure or anonymisation, backup.
- Data: customers' identity and contact details, IMEI / serial numbers, encrypted unlock codes, photos and signatures, payments and balances, messages, notes; shop staff data.
- Data subjects: the shop's customers and staff.
No sensitive data is expected; the Controller must not enter any.
Processor obligations
- Process data only on the Controller's documented instructions (terms of use, settings, user actions).
- Ensure confidentiality of authorised persons; support access only through logged impersonation.
- Apply the security measures of annex 2 and isolate each shop's data.
- Forward within 5 business days any request received directly from a data subject, and assist the Controller.
- Notify any personal data breach without undue delay and at the latest 48 hours after becoming aware of it.
- Make available the information needed for audits (once a year, 30 days' notice) and keep a record of processing.
Sub-processors and transfers
The Controller gives general authorisation for the sub-processors listed on the “Sub-processors” page. 30 days' notice is given before any addition or replacement; the Controller may object on legitimate grounds, failing which it may terminate without penalty.
Data is hosted in the European Union ([TO BE COMPLETED]). For any transfer outside the EU, appropriate safeguards apply (standard contractual clauses for EU shops: [TO BE COMPLETED BY COUNSEL]).
Controller obligations and data subject rights
The Controller must inform its customers (receipt notice, display), have a legal basis, keep data accurate, manage its staff's access, file its own register with the ANPDP if required and not enter sensitive data.
For data subject requests it uses the app's functions: export, rectification, anonymisation. Financial entries are kept in anonymised form.
Return and deletion
When the service ends, the owner can export a full backup. Data is purged after the retention period (90 days by default, final value to be confirmed); RepariDZ's own accounting records are kept for 10 years; backups expire within 30 days.
Governing law, liability and acceptance
Governing law and jurisdiction: [TO BE COMPLETED BY COUNSEL]. Liability: as per the terms of use [TO BE COMPLETED BY COUNSEL].
Acceptance is given online at sign-up (DPA version, date and time are recorded) or by signature on request.
Annex 2 — Technical and organisational measures
TLS and at-rest encryption; field-level encryption of unlock codes (per-shop key); hashed passwords; limited one-time codes; mandatory two-factor authentication for administration; per-shop data isolation and leakage tests; roles and permissions; tamper-resistant audit log; rate limiting; encrypted backups with restore tests; encrypted local database on devices and remote revocation; secrets management; dependency scanning; penetration test before launch and yearly; incident response plan.