1. Scope

This Data Processing Addendum ("DPA") supplements the How To CSV Terms & Conditions and applies where LINEGON S.R.L. processes personal data on behalf of a customer ("Controller") in the course of providing the Service.

2. Roles

For account and usage data, LINEGON acts as data controller (see our Privacy Policy). Where a customer uploads personal data to server-side features of the Service, LINEGON acts as data processor and the customer as controller.

3. Processing Instructions

LINEGON will process personal data only on documented instructions from the Controller, including regarding international transfers, unless required otherwise by applicable law.

4. Sub-processors

LINEGON may engage sub-processors (e.g. hosting and infrastructure providers) to support the Service. LINEGON remains responsible for sub-processor compliance with data protection obligations equivalent to those in this DPA.

5. Security Measures

Encryption of data in transit (TLS).
Access controls limiting personal data access to authorized personnel.
Client-side processing by default, minimizing server-side exposure of file contents.

6. Data Subject Requests

LINEGON will assist the Controller, insofar as reasonably possible, in responding to data subject requests concerning personal data processed under this DPA.

7. Breach Notification

LINEGON will notify the Controller without undue delay after becoming aware of a personal data breach affecting data processed under this DPA.

8. Deletion / Return of Data

Upon termination of the Service relationship, LINEGON will delete or return personal data processed on the Controller's behalf, except where retention is required by law.

9. Contact

For DPA-related inquiries, contact info@linegon.com.

Data Processing Addendum