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Data Processing Agreement

OMINEX provides a standard GDPR Art. 28-aligned Data Processing Agreement to all customers as part of the Master Subscription Agreement. The DPA covers controller-to-processor terms, sub-processor authorization, transfer mechanism, breach notification, audit rights, and termination return / deletion.

What's in the DPA

  • Controller-to-processor scope and instructions (Art. 28(3))
  • Confidentiality and personnel obligations
  • Technical and Organizational Measures (TOMs) annex (Art. 32)
  • General sub-processor authorization with 30-day notice and objection
  • Assistance with data subject rights, DPIAs, and supervisory consultation
  • 72-hour Personal Data Breach notification commitment
  • Annual audit rights with 60-day notice; SOC 2 / ISO reports on request
  • Standard Contractual Clauses (2021/914 Module 2) for international transfers
  • UK Addendum and Swiss carve-outs
  • Return or deletion at termination
  • CCPA / CPRA service-provider terms

Annexes

  1. Annex 1: List of parties.
  2. Annex 2: Description of processing — purposes, categories of data subjects and personal data, retention.
  3. Annex 3: Technical and Organizational Measures, covering encryption, access control, network, application, operational, personnel, vendor management, incident response, data minimization, physical security, and logging.
  4. Annex 4: Sub-processors — current list at /sub-processors.

How to receive the DPA

The current DPA template is available to evaluators and prospective customers under NDA. Existing customers receive the DPA as a deliverable of contract execution. To request a copy:

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