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Data Processing Agreement Last updated 1 March 2026 · Applies to every ACL Software BV product When you store personal data about your own customers or staff in our products, you are the controller and ACL Software BV is the processor. This document sets out the terms of that relationship under Article 28 GDPR. 1. Subject matter and duration We process personal data on your documented instructions for as long as your company holds an account with us, and delete or return it within 30 days of termination. 2. Nature and purpose Hosting, storing, transmitting and displaying the data you enter, so that the products you have enabled function as described. 3. Categories of data and data subjects Data subjects: your staff who hold accounts, and any individuals you record inside a product — for example the customer named on a booking. Data: names, email addresses, and whatever free-text content you choose to enter. Do not store special-category data without telling us first. 4. Our obligations We process only on your instructions, and tell you if an instruction appears to breach the GDPR. Everyone with access is bound by confidentiality. We keep the technical and organisational measures described in our Privacy Policy. We help you respond to data-subject requests and to security incidents. We notify you without undue delay after becoming aware of a personal data breach. 5. Sub-processors We use EU-based hosting and database providers as sub-processors. We will give you notice before adding or replacing one, and you may object on reasonable data-protection grounds. 6. International transfers Personal data stays within the European Economic Area. 7. Audits On reasonable notice and no more than once a year, we will provide the information needed to demonstrate compliance with this agreement. Questions about this document? Write to privacy@acsft.com. See also our Terms of Service, Privacy Policy and Data Processing Agreement.