Data Processing Agreement

Last updated: March 1, 2026

1. Scope and Purpose

This DPA supplements the Terms of Service and applies when CloudLink processes personal data on your behalf as a "Processor" under GDPR or equivalent laws.

2. Data Processing Details

Categories of data subjects: your employees, contractors, and end-users. Types of personal data: name, email, IP address, usage telemetry. Processing purposes: service delivery, support, billing.

3. Processor Obligations

CloudLink shall: (1) process data only on documented instructions, (2) ensure personnel are bound by confidentiality, (3) implement appropriate technical and organizational measures, (4) assist with data subject rights requests.

4. Sub-Processors

Current sub-processors: AWS (infrastructure), Stripe (billing), Clerk (authentication), Sentry (error tracking). We notify you 30 days before adding a new sub-processor.

5. International Transfers

Data is processed in the United States. For EU transfers, we rely on Standard Contractual Clauses (Module 2: Controller-to-Processor) adopted by the European Commission.

6. Data Breach Notification

We will notify you of a personal data breach without undue delay and no later than 72 hours after becoming aware of the breach, providing details required under Article 33 GDPR.