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Data Processing Agreement (GDPR (EU))

Version 1 • Generated on May 19, 2026

Data Processing Agreement - Econtime Consultants

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Data Processing Agreement (DPA)

This Data Processing Agreement ("DPA") is entered into by and between Econtime Consultants (the "Controller") and the Service Provider (the "Processor") identifying themselves in the underlying Service Agreement.

1. Definitions and Scope of Processing

This DPA applies to the processing of personal data by the Processor on behalf of Econtime Consultants. Pursuant to [Article 28], the subject-matter, duration, nature, purpose, type of personal data, and categories of data subjects are as defined in the primary Service Agreement.

2. Data Processing Instructions

The Processor shall process personal data only on documented instructions from the Controller, unless required to do otherwise by Union or Member State law. As required by [Article 28], the Processor shall immediately inform the Controller if, in its opinion, an instruction infringes GDPR requirements.

3. Confidentiality and Security Obligations

The Processor shall ensure that persons authorized to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality [Article 28].

Taking into account the state of the art and risks of varying likelihood and severity, the Processor shall implement technical and organizational measures as required by [Article 32], including:

The pseudonymisation and encryption of personal data;

The ability to ensure ongoing confidentiality, integrity, availability, and resilience of processing systems;

The ability to restore availability and access in a timely manner in the event of a physical or technical incident;

A process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures.

4. Sub-processor Management

In accordance with [Article 28], the Processor shall not engage another processor (Sub-processor) without prior specific or general written authorization of the Controller. The Processor shall ensure that the same data protection obligations as set out in this DPA are imposed on that Sub-processor by way of a contract.

5. Data Subject Rights Assistance

The Processor shall, taking into account the nature of the processing, assist the Controller by appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights (access, rectification, erasure, restriction, portability, and objection) [Article 28].

6. International Data Transfers

Any transfer of personal data to a third country shall take place only in compliance with [Article 44]. In the absence of an adequacy decision, the Processor shall ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) adopted by the Commission, as specified in [Article 46], ensuring that enforceable data subject rights and effective legal remedies remain available.

7. Breach Notification Procedures

In the case of a personal data breach, the Processor shall notify the Controller without undue delay. Per [Article 33], the Controller is required to notify the supervisory authority within 72 hours of becoming aware of the breach. The Processor must provide the Controller with:

The nature of the breach and categories of data subjects/records involved;

The likely consequences of the breach;

The measures taken or proposed to address the breach.

If the breach is likely to result in a high risk to the rights and freedoms of natural persons, the Controller shall communicate the breach to the data subject without undue delay [Article 34].

8. Audit Rights and Compliance Monitoring

The Processor shall make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in [Article 28] and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller.

9. Data Deletion or Return

At the choice of the Controller, the Processor shall delete or return all personal data to the Controller after the end of the provision of services relating to processing, and delete existing copies unless Union or Member State law requires storage of the personal data [Article 28].

10. Liability and Maturity Assessment

Control Domain

Maturity (0-5)

Impact

Risk Score (LxI)

Processing Security

High

Medium (2x4)

Breach Notification

Critical

Low (1x5)

The Processor remains fully liable to the Controller for the performance of Sub-processors' obligations. Assessment of security levels must account for risks of accidental or unlawful destruction, loss, alteration, or unauthorized disclosure [Article 32].

LEGAL DISCLAIMER: This document was generated by your Virtual DPO for compliance documentation purposes only and does not constitute legal advice. Consult qualified legal counsel before implementation.

This assessment is generated using AI-assisted analysis and does not constitute legal advice. Organizations should consult qualified legal counsel for regulatory interpretation.

Generated by Virtual DPO • Document ID: c50051be-9e08-40a4-9947-f4dcc2cf2ab0

Privacy Notice (GDPR (EU))

Version 1 • Generated on May 19, 2026

Privacy Notice - Econtime Consultants

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Privacy Notice: Econtime Consultants

Last Updated: October 2023

Econtime Consultants ("the Company", "we", "us") is committed to protecting the privacy and security of your personal data. This Privacy Notice is provided in accordance with Article 12 and Article 13 of the GDPR (EU) to ensure transparent communication regarding our data processing activities.

1. Data Collection and Purpose

As a consulting firm, we process personal data to provide professional services, maintain business operations, and meet regulatory requirements. In accordance with Article 5, we adhere to the principles of purpose limitation and data minimisation.

Client Data: Name, professional contact details, financial information, and business records provided during the course of consulting engagements.

Inquiry Data: Information provided via our website or email for the purpose of initiating a project or contract.

Administrative Data: Information required for billing, tax compliance, and legal record-keeping.

2. Lawfulness of Processing

In compliance with Article 6, Econtime Consultants processes your data under the following legal bases:

Performance of a Contract [Art. 6(b)]: Processing is necessary to fulfill our consulting agreements with you or to take steps at your request prior to entering into a contract.

Legal Obligation [Art. 6(c)]: Processing is necessary for compliance with EU or Member State legal obligations (e.g., tax reporting).

Legitimate Interests [Art. 6(f)]: Processing is necessary for the legitimate interests pursued by Econtime Consultants, such as improving our services, business development operations, and ensuring network security, provided such interests are not overridden by your fundamental rights.

Consent [Art. 6(a)]: Where you have given clear consent for a specific purpose (e.g., marketing newsletters). You may withdraw consent at any time as per Article 13(h).

3. Data Subject Rights

Under the GDPR, you have the following rights regarding your personal data:

Right of Access [Art. 15]: You may request confirmation of processing and a copy of your personal data.

Right to Rectification [Art. 16]: You may request the correction of inaccurate or incomplete data.

Right to Erasure ('Right to be Forgotten') [Art. 17]: You may request data deletion when it is no longer necessary for the original purpose or where you have withdrawn consent.

Right to Restriction of Processing [Art. 18]: You may request that we limit how we use your data under specific circumstances.

Right to Data Portability [Art. 20]: You may request your data in a structured, commonly used, and machine-readable format to transmit to another controller.

Right to Object [Art. 21]: You may object to processing based on legitimate interests or for direct marketing.

To exercise these rights, please contact our Data Protection Officer. We will respond within one month, as specified in Article 12.

4. Data Retention

In accordance with Article 5(e) (Storage Limitation), we keep personal data in a form which permits identification for no longer than is necessary for the purposes for which the personal data are processed. Our retention criteria include:

Contractual Records: Retained for 7 years following the conclusion of the contract to comply with financial and legal obligations.

Communication Records: Retained for 2 years after the last point of contact unless a contract is established.

5. Security Measures

Following the principles of Article 5(f) (Integrity and Confidentiality), Econtime Consultants implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk. These include encryption of sensitive data, access controls, and regular audits of our processing activities.

6. International Data Transfers

Pursuant to Article 44, any transfer of personal data to a third country shall only occur if the conditions of the GDPR are met. In the absence of an adequacy decision by the European Commission, Econtime Consultants utilizes appropriate safeguards as defined in Article 46, specifically Standard Contractual Clauses (SCCs), to ensure the protection of your data remains equivalent to EU standards.

7. Contact Information and Complaints

For inquiries regarding your data or to exercise your rights under Article 13, please contact:

Data Protection Officer

Econtime Consultants

Email: dpo@econtime.eu

As per Article 13(i), you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

Maturity Level Indicator: Level 4 (Managed) - Policies and procedures are defined and actively communicated to data subjects.

This assessment is generated using AI-assisted analysis and does not constitute legal advice. Organizations should consult qualified legal counsel for regulatory interpretation.

Generated by Virtual DPO • Document ID: 277bc5b5-4a7e-48b7-8498-d19b53cfccd5

Data Processing Agreement (GDPR (EU))

Privacy Notice (GDPR (EU))

Econtime Consultants is a Service of Copra International LLC