Data Processing Agreement
Last Updated: February 2026
Version 1.0
1. Purpose
This Data Processing Agreement (DPA) applies to the processing of personal data of users located in the European Union and other jurisdictions with similar data protection laws.
2. Roles
Xanivar acts as a Data Processor on behalf of users who are Data Controllers under GDPR. Users remain responsible for ensuring lawful processing of their own personal data.
3. Scope of Processing
Xanivar processes personal data only to the extent necessary to:
- Provide the Platform services
- Comply with legal obligations
- Protect rights and safety
4. Processing Details
Types of Data: Name, email, IP address, usage data, payment information
Processing Purpose: Service delivery, analytics, legal compliance
Duration: For the duration of service plus any legally required retention
5. Data Subject Rights
Xanivar ensures all GDPR rights are honored:
- Right to access
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right to data portability
- Right to object
6. Security Measures
Xanivar implements technical and organizational measures to protect personal data, including:
- Encryption in transit and at rest
- Access controls and authentication
- Regular security audits
- Incident response procedures
7. Sub-processors
Xanivar may engage sub-processors for services including hosting (Supabase), payments (Stripe), and analytics. Users have the right to object to new sub-processors.
8. Data Transfers
Personal data may be transferred outside the EU. Xanivar ensures appropriate safeguards through Standard Contractual Clauses or other lawful mechanisms.
9. Data Breaches
Xanivar will notify users of any data breach within 72 hours or as required by law. Users will receive information about the breach and mitigation measures.
10. Data Deletion
Users may request deletion of their data at any time (subject to legal retention requirements). Xanivar will comply within 30 days of verification.
11. Audit and Cooperation
Xanivar cooperates with data protection authorities and provides necessary documentation for GDPR compliance audits.
12. Term and Termination
This DPA remains in effect for as long as the Platform services are provided. Upon termination, Xanivar will delete or return personal data as directed.
13. Contact
For DPA-related questions, contact our Data Protection Officer at dpo@xanivar.com.