DPA for the Support Load Report.
A short, two-page GDPR-compliant DPA covering only what this engagement actually does. We countersign it before you upload anything.
Parties and roles
For the purposes of GDPR (Regulation (EU) 2016/679):
- You (the operator) are the Controller. The chat data originates from your player relationships; you decide what is included in the export and for what purpose it is shared.
- We are the Processor. We handle the export solely on your written instructions, within the limits set out in the data note and this DPA. No re-use, no independent decision-making, no onward sharing beyond the named sub-processors.
The legal entity signing as Processor is Gazolin Production SRL, Baia Mare, Romania, trading as Arctura. Full company details on the contact page.
Available on request. The template is finalised per operator (your legal entity name, jurisdiction, and any specific clauses your counsel wants to add), so we don't post a generic PDF.
Email viktor@arctura.eu — say "DPA for the load report" and we send it back the same working day.
What it covers
- Subject-matter and duration. Analysis of a chat export you send us; anonymisation on receipt; deletion of the original within 24 hours; deletion of anonymised working data 7 days after report delivery.
- Nature and purpose. Classification of conversations to produce your Support Load Report. No re-use for anything else without your written consent.
- Categories of data subjects. Your players and agents whose messages appear in the export.
- Categories of personal data. Whatever your helpdesk export contains at the point of upload; anonymised at receipt as described in the data note.
- Security measures. EU-only storage, encryption in transit and at rest, access limited to two named individuals, deletion logs.
- Sub-processors. Named. LLM provider under a no-training contract; storage provider (Hetzner, Frankfurt). Any change notified in advance.
- International transfers. None outside the EU/EEA for the chat data itself.
- Assistance and audit rights. Standard. Deletion certificate issued on request.
Why we don't post a public PDF
A DPA that isn't specific to two named parties is a template, not an agreement. We'd rather send you one with your legal name and jurisdiction already filled in — it's less friction for your counsel and less risk of a stale version lingering in someone's inbox.