Data Processing Agreement

Our Data Processing Agreement ("DPA") forms part of the Terms of Service and governs how Black Ice processes personal data on your behalf as a processor under GDPR Article 28. It covers the scope of processing, security obligations, sub-processor management, international transfers (SCCs), and data subject rights cooperation.

A countersigned PDF version of the DPA is available on request for any paid workspace. Workspaces on the Free tier are covered by the standard terms incorporated into the Terms of Service.

• Roles: Customer is the controller; Black Ice is the processor.
• Sub-processors are listed on the Sub-processors page with 30-day change notice.
• Cross-border transfers rely on EU Standard Contractual Clauses (2021/914).
• Retention: on termination you have 30 days to export; data is then deleted from production, with backups expiring within 7 days.
• Customer content is never used to train foundation models, our own or third-party.

To countersign, email us via the contact form below and we'll send you a DocuSign link within one business day.