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Data Processing Agreement

Last updated: 4 September 2026 (review by counsel pending)

1. Subject matter

This Data Processing Agreement ("DPA") forms part of the Gathmo Terms of Service and governs the processing of personal data by EasyTrafficBot UG (haftungsbeschränkt), trading as Gathmo ("Processor") on behalf of the Customer ("Controller") in connection with the Gathmo platform.

2. Nature and purpose of processing

Gathmo processes personal data (event guest uploads including photos, videos, voice messages, and associated metadata) to provide the event-media platform services described in the Terms of Service.

3. Processor obligations

Gathmo will: process personal data only on documented instructions from the Controller; ensure that authorised personnel are bound by confidentiality; implement appropriate technical and organisational measures under GDPR Art. 32; and assist the Controller with data subject rights requests.

4. Sub-processors

Gathmo uses these sub-processors: Spaceship, a Namecheap brand (server hosting in Phoenix, Arizona, USA), Cloudflare (media storage and voice transcription), Stripe (payments), Resend (email), Google (sign-in, analytics, advertising) and PostHog EU (product analytics). Gathmo will notify the Controller of any intended change to this list.

5. Data transfers

Personal data is stored and processed in the United States, and media additionally on Cloudflare. Transfers out of the EEA and the UK are made under GDPR Chapter V: the EU standard contractual clauses agreed with each provider and, where that provider is certified, the EU-US Data Privacy Framework, together with the supplementary measures those safeguards require.

6. Return and deletion

Upon termination of the services, Gathmo will, at the Controller's choice, delete or return all personal data and delete existing copies unless EU or member-state law requires storage of the personal data.

Questions about this DPA? Email privacy@gathmo.com