Draft, last updated 4 October 2026
Data Processing Agreement
1. What we process and why
- Subject matter: creating meeting pages and wallet passes for your bookings and keeping them up to date.
- Duration: as long as you use the service, plus the deletion periods below.
- Data subjects: people who book meetings, calls or webinars with you (attendees).
- Personal data: name, email address, meeting title, time and time zone, join link and reschedule link, whether the meeting page was opened and the pass added, Apple Wallet device identifiers and push tokens, Google Wallet object ids, and the attended or no-show outcome you record.
- Special categories: none are needed. Do not put sensitive data (for example health information) in meeting titles or descriptions.
2. Your instructions
We process attendee data only to provide the service as you configure it, and on your other documented instructions. If we believe an instruction breaks data protection law, we will tell you. If the law requires us to process data in another way, we will tell you first unless the law forbids it.
3. Confidentiality
Everyone at Coldabry LLC who can access attendee data is bound by confidentiality and accesses it only when needed to run or support the service.
4. Security measures
- Encryption in transit (TLS) for all web traffic and API calls.
- Agency signing certificates and keys encrypted at rest with AES-256-GCM.
- Webhooks accepted only with a valid signature or secret; meeting links use random, unguessable tokens; attendee emails never appear on passes or in URLs.
- Hosting in EU data centres (Contabo GmbH, Germany) with restricted administrative access and SSH keys only.
- Regular database backups, rotated within 30 days.
- Apple device registrations deleted when the pass is removed; demo data deleted after 24 hours.
- Rate limiting on public endpoints and dependency updates as part of normal maintenance.
5. Sub-processors
You authorise us to use the sub-processors below. We bind each of them to data protection terms at least as protective as this agreement and remain responsible for them. We will tell you by email at least 30 days before adding or replacing a sub-processor, and you may object on reasonable data protection grounds. If we cannot resolve the objection, you may end the agreement.
| Sub-processor | What it does for us | Where | Transfer safeguard |
|---|---|---|---|
| Contabo GmbH | Hosting of the application, database and backups | European Union (Germany) | None, data stays in the EU |
| Apple Inc. (Apple Push Notification service) | Telling Apple Wallet that a pass changed, using the device push token | USA | EU-US Data Privacy Framework, Standard Contractual Clauses |
| Google LLC (Google Wallet API) | Creating and updating Google Wallet passes and their notifications | USA and other Google locations | EU-US Data Privacy Framework, Standard Contractual Clauses |
| Sendinblue SAS (Brevo) | Sending account emails and, if the agency turns it on, the meeting pass email | European Union (France) | None for storage; Brevo's own sub-processors are covered by its DPA |
6. International transfers
Data is stored in the EU. Where a sub-processor processes data outside the EU or EEA, the transfer is covered by the EU-US Data Privacy Framework or the European Commission's Standard Contractual Clauses. As a US company, Coldabry LLC enters into the Standard Contractual Clauses (Module 2 or 3 as applicable) with you where required; they take precedence over this agreement if the two conflict.
7. Helping you with requests and duties
- If an attendee contacts us directly, we pass the request to you without undue delay and do not answer it ourselves unless you ask us to.
- The dashboard lets you view and delete bookings. For anything else, we help you respond to access, correction, deletion and other requests.
- We give you the information you reasonably need for data protection impact assessments and consultations with authorities.
8. Personal data breaches
If we become aware of a breach affecting your attendee data, we will tell you without undue delay and in any case within 48 hours. We will share what we know (what happened, the data and people affected, likely consequences, and what we are doing), and keep you updated as we learn more, so you can meet your own 72-hour notification duty.
9. Deletion at the end
When you close your account or the agreement ends, we delete attendee data within 30 days, and it leaves our rolling backups within a further 30 days. Before closing, you can ask us for an export of your bookings. We keep data longer only where the law requires it.
10. Audits
We will make available the information needed to show we comply with this agreement and Article 28. You may audit us, or have an independent auditor do so, once a year with 30 days' notice and at your own cost, in a way that does not disrupt the service or expose other customers' data.
11. Liability and order of documents
Liability under this agreement follows the limits in the Terms of Service, unless the law does not allow it. If this agreement and the terms conflict on data protection, this agreement wins.
12. Contact
Coldabry LLC, 1209 Mountain Road Pl NE #4337, Albuquerque, NM 87110, USA. Email: rk@coldabry.com.