Data Processing Agreement

The Processor provides ClipnClip, a service to record, store, transcribe, edit and share videos. In doing so it processes personal data on behalf of the Controller, only on the Controller's documented instructions, as set out in Art. 28 GDPR and this DPA.

The Controller's instructions are the terms, this DPA and the settings the Controller chooses in the product (storage mode, AI, link and retention settings).

This DPA applies for as long as the Processor processes personal data for the Controller, and ends when all of it has been deleted or returned, including the 30-day grace period after a workspace is deleted.

• Hosting video files and metadata (ClipnClip Cloud), or directing uploads to the Controller's own bucket.
• Transcoding, thumbnails, transcripts, captions and, when switched on, AI titles, summaries and chapters.
• In own-bucket mode, video is processed ephemerally: it is read from the Controller's bucket, processed in an isolated sandbox, written back to that bucket, and never stored on ClipnClip servers. With "Server processing off", ClipnClip does not read the video at all.
• Showing videos, comments and reactions to the people the Controller shares them with, and viewer insights where viewers consent.

The Controller must not upload special categories of data (Art. 9 GDPR) unless it has a lawful basis and has assessed the risk.

• Process personal data only on documented instructions, and tell the Controller if an instruction appears to break data protection law.
• Ensure everyone with access is bound by confidentiality.
• Help the Controller answer data subject requests, mainly through the self-serve export and deletion tools.
• Help the Controller with data protection impact assessments and consultations with authorities where needed.
• At the end of the service, delete all personal data (or return it through the export) unless law requires keeping it.

• Encryption in transit (TLS 1.2 or later) and at rest for databases, backups and cloud storage.
• Own-bucket access keys encrypted with a per-workspace data key, itself encrypted with the application key; never returned by the API.
• Video served only through short-lived presigned URLs; uploads go directly to storage.
• Media processing in a sandbox without network access, with temporary files deleted after each job.
• Role-based access within workspaces; audit log of exports, deletions, role and link changes.
• Least-privilege staff access, logged; backups tested regularly (placeholder: frequency).

More detail on the security page.

The Controller authorises the sub-processors listed on the sub-processors page. The AI provider is used only when ClipnClip-included AI is switched on. The Processor gives at least 30 days' notice of a new sub-processor on that page and by email to workspace owners; the Controller may object on reasonable grounds.

In own-bucket mode, the bucket provider is engaged by the Controller directly and is the Controller's processor, not a sub-processor of ClipnClip.

The Processor notifies the Controller without undue delay, and in any case within 72 hours of becoming aware of a personal data breach, with what is known about its nature, the data and people affected, likely consequences and the measures taken. Updates follow as more is learned.

The Processor makes available the information needed to show compliance with Art. 28, including security documentation on request. The Controller may audit once a year with 30 days' notice, at its own cost, under confidentiality, without disrupting the service.

Where personal data is transferred outside the EEA, the parties rely on an adequacy decision or the Standard Contractual Clauses (Commission Decision 2021/914), Module Two (controller to processor) or Module Three (processor to processor), incorporated by reference. Placeholder: annexes, docking clause and supervisory authority.

Workspace admins accept this DPA in Settings → Data & GDPR; ClipnClip records the name, workspace, time and DPA version. A countersigned copy is available on request from privacy@[domain].

Processor: [Company name]. Controller: the organisation named in the workspace's billing details.