Data processing addendum

How Wrenship processes personal data in the apps and databases you host, on your instructions.

Last updated: [date]

This addendum is part of the Terms of Service between you ("Customer") and [Wrenship legal entity] ("Wrenship"). It applies when Wrenship processes personal data on your behalf as part of hosting your apps and databases ("Customer Data").

1. Roles

You are the controller of Customer Data and decide why and how it's processed. Wrenship is your processor and processes it only to provide the Service, following your instructions. Your use of the Service, its settings and these terms are your instructions.

2. What's processed

• Subject matter: hosting, running, backing up and serving your apps and databases.
• Data subjects and categories: whatever your apps collect, as you decide. Wrenship doesn't inspect Customer Data except to provide the Service, to keep it secure, or when the law requires it.
• Duration: for as long as you use the Service, plus the backup period.

3. Wrenship's obligations

Wrenship will:

• process Customer Data only on your documented instructions, and tell you if an instruction seems to break data protection law;
• make sure people with access are bound to confidentiality;
• apply the security measures in section 5;
• help you, as far as it reasonably can, to answer data subjects' requests and to meet your obligations on security, breach notification and impact assessments;
• notify you without undue delay, and within 48 hours, after becoming aware of a personal data breach affecting Customer Data;
• delete Customer Data when you delete it or close your account, apart from backups that expire on their schedule (at most 90 days), unless the law requires keeping it;
• make available the information needed to show compliance, and allow audits as described in section 7.

4. Subprocessors

You authorize Wrenship to use these subprocessors for Customer Data:

Wrenship will give at least 30 days' notice of a new subprocessor by email and on this page. You may object on reasonable data protection grounds; if we can't resolve it, you may end the affected service and get a refund of prepaid fees for it. Wrenship stays responsible for its subprocessors.

5. Security measures

• Servers accept no inbound connections; traffic arrives through an encrypted tunnel from the edge.
• No remote shell or SSH; management only through signed, short-lived commands from a fixed catalog.
• Each app runs as its own user in a sandbox with read-only code.
• Secrets are encrypted for the destination server before transfer and at rest.
• Databases listen only inside the server. Backups are encrypted before they leave it.
• Automatic security updates; access to production systems limited to authorized staff, with sign-in protected by strong authentication and logged.

See Security for details.

6. International transfers

Customer Data stays in the region you choose for your server, except where you configure otherwise (for example by serving files through the global edge). Where a transfer outside the EEA, UK or Switzerland happens, the Standard Contractual Clauses (processor module) apply, which are incorporated by reference.

7. Audits

Wrenship will answer reasonable security questionnaires once a year, and share summaries of independent assessments when available. If that isn't enough to show compliance, you may audit with 30 days' notice, at your cost, during business hours, under confidentiality, and without access to other customers' data.

8. Liability

The limits in the Terms of Service apply to this addendum.

9. Contact

[privacy@wrenship.com] · [Wrenship legal entity], [registered address]