Processor Agreement
Parties:
1. Client:
2. Processor: NewSpirits
This agreement pertains to the assignment between the client and NewSpirits.
Article 1. Roles
1. The client is the data controller.
2. NewSpirits is the processor to the extent that it processes personal data on behalf of
the client.
3. NewSpirits processes personal data only according to the instructions of
the client.
Article 2. Purpose of processing
NewSpirits processes personal data solely for the execution of the assignment,
for example:
● Intake;
● Project management;
● Brand development;
● Marketing support;
● Distribution guidance;
● Customer communication;
● Production coordination;
● Logistical alignment.
Article 3. Types of personal data
Depending on the assignment, it may involve:
● Names;
● Email addresses;
● Phone numbers;
● Company information;
● Addresses;
● Customer data;
● Leads;
● Order details;
● Marketing preferences;
● Communication data
Article 4. Involved parties
The processing may relate to:
● Customers;
● Leads;
● Suppliers;
● Employees;
● Contacts;
● Newsletter recipients;
● Distributors;
● Hospitality or retail contacts
Article 5. Security
NewSpirits takes appropriate technical and organizational measures, such as:
● Limited access;
● Confidentiality;
● Strong passwords;
● Two-step verification where possible;
● Secure storage;
● Careful sharing of files;
● Limiting access to necessary persons
Article 6. Sub-processors
1. NewSpirits may engage sub-processors if necessary.
2. Think of hosting parties, software suppliers, designers, marketing tools,
production partners, carriers, and other service providers.
3. NewSpirits ensures appropriate agreements with sub-processors where necessary
Article 7. Data breaches
1. NewSpirits reports a data breach to the client without unreasonable delay as soon as
NewSpirits becomes aware of it.
2. The client is responsible for assessment and any notification to the
supervisory authority or data subjects.
Article 8. Rights of data subjects
1. If a data subject contacts NewSpirits directly, NewSpirits
forwards the request to the client.
2. NewSpirits reasonably assists the client with requests from data subjects.
3. Additional work may be charged as extra work.
Article 9. Deletion or return
After the termination of the assignment, NewSpirits deletes personal data or returns it, unless retention is necessary for legal obligations, administration, evidence, or legitimate interests.
Article 10. Liability
The liability of NewSpirits under this processing agreement is limited as stated in the general terms and conditions or main agreement.