📝 Draft for review — this document is a working template and is not yet legally reviewed. Placeholders in yellow must be completed before launch.
Data Processing Addendum
Effective date: 2026-07-13 · Service: IPM (ipuipu.com), operated by [Company legal name] (“IPM”, “we”, “us”). Contact: [legal@your-domain].
This Data Processing Addendum (“DPA”) supplements the Terms where IPM processes personal data on your behalf as a processor.
Roles
You are the controller; IPM is the processor. We process personal data only on your documented instructions to provide the service.
Sub-processors & security
We engage sub-processors under written contract and maintain appropriate technical and organizational measures (see Security).
Data subject requests & breach
We assist you in responding to data-subject requests and notify you without undue delay upon becoming aware of a personal data breach.
[Attach standard contractual clauses / sub-processor list before launch.]