Data Processing Agreement

1. Definitions

2. Subject matter and duration

This Agreement governs the Processor's processing of Personal Data on behalf of the Controller for the purpose of providing the Services. It remains in force for as long as the Processor processes Personal Data on behalf of the Controller.

3. Nature and purpose of processing

The Processor will process Personal Data solely for the following purposes:

The Processor will not process Personal Data for any purpose other than those documented by the Controller.

4. Types of personal data and categories of data subjects

4.1 Types of Personal Data

4.2 Categories of data subjects

The Controller is responsible for ensuring it has lawful authority to provide all such data.

5. Obligations of the Controller

The Controller agrees to:

The Controller indemnifies the Processor against claims arising from unlawful or unauthorised data submission.

6. Obligations of the Processor

6.1 Process only on documented instructions

Process Personal Data only on the Controller's documented instructions, unless required by law.

6.2 Confidentiality

Ensure all personnel authorised to process Personal Data are bound by confidentiality obligations.

6.3 Security measures

Implement appropriate technical and organisational measures to protect Personal Data, including encryption, access controls, secure hosting, and regular security testing.

6.4 Sub-processors

The Processor may engage sub-processors to support the Services. The Processor will:

6.5 Assistance to the Controller

The Processor will assist the Controller in:

6.6 Data breach notification

The Processor will notify the Controller without undue delay upon becoming aware of a Personal Data breach.

6.7 Data transfers

The Processor will not transfer Personal Data outside the UK/EEA without appropriate safeguards, such as adequacy decisions, Standard Contractual Clauses (SCCs), or additional technical and organisational protections.

7. Data subject rights

The Processor will assist the Controller in fulfilling requests from data subjects, including access, rectification, erasure, restriction, objection, and data portability. The Processor will not respond directly to data subjects unless instructed by the Controller.

8. Return or deletion of data

Upon termination of the Services, the Processor will:

Competition results may be retained in anonymised or aggregated form.

9. Audits and inspections

The Controller may request information necessary to demonstrate compliance. Formal audits may be conducted with reasonable notice, without disrupting platform operations, and subject to confidentiality obligations.

10. Liability

Each party's liability under this Agreement is subject to the limitations set out in the main Terms & Conditions, except where prohibited by law.

11. Governing law

This Agreement is governed by the laws of England and Wales. Any disputes shall be resolved exclusively in the courts of England and Wales.

12. Entire agreement

This DPA forms part of the Terms & Conditions between the parties. In the event of conflict, this DPA prevails with respect to data protection matters.