Data Processing Agreement (DPA)
(version 1.0 dated 04.02.2026)

This Data Processing Agreement (“Agreement” or “DPA”) forms part of the Terms and Conditions and is entered into between:

Asset Payments Sp. z o.o., Bohaterów Warszawy 23/2, 02-495 Warsaw, Poland (“Processor”)

and the customer using the Service (“Controller”).

This Agreement applies where the Processor processes Personal Data on behalf of the Controller in the course of providing the Service, in accordance with Article 28 of Regulation (EU) 2016/679 (“GDPR”).

1. Definitions

Terms used but not defined in this Agreement shall have the meaning given to them in the GDPR or the Terms and Conditions.

2. Subject Matter and Duration

The subject matter of this Agreement is the processing of Personal Data by the Processor on behalf of the Controller for the purpose of providing the Service.

This Agreement remains in force for the duration of the underlying service agreement.

3. Nature and Purpose of Processing

The Processor provides a SaaS platform that receives webshop order data via webhooks and forwards such data to third-party systems (including CRM, accounting, fiscal, or management platforms) as configured by the Controller.

Processing activities include receiving, storing temporarily, transforming, and transmitting data in an automated manner.

4. Categories of Data Subjects and Personal Data

4.1 Data Subjects

  • Customers or buyers of the Controller
  • Employees or representatives of the Controller

4.2 Categories of Personal Data

  • Identification data (name, email, phone number)
  • Order and transaction data
  • Billing and invoicing information
  • Cart contents and purchase details
  • Technical metadata related to orders

5. Roles and Responsibilities

The Controller determines the purposes and means of processing Personal Data. The Processor processes Personal Data only on documented instructions from the Controller, unless required to do so by Union or Member State law.

6. Controller Obligations

The Controller represents and warrants that:

  • It has a valid legal basis for processing and transferring Personal Data
  • It has informed data subjects as required by GDPR
  • Its instructions comply with applicable data protection laws
  • It is responsible for the accuracy and legality of the data provided

7. Processor Obligations

The Processor shall:

  • Process Personal Data only in accordance with this Agreement
  • Ensure persons authorized to process data are bound by confidentiality
  • Implement appropriate technical and organizational security measures
  • Not sell or use Personal Data for its own purposes

8. Subprocessors

The Controller authorizes the Processor to engage subprocessors, including but not limited to: cloud infrastructure providers, payment processors, and email delivery services.

The Processor shall ensure that subprocessors are bound by data protection obligations equivalent to those set out in this Agreement.

9. International Data Transfers

Personal Data may be transferred outside the European Economic Area only where appropriate safeguards are in place, including standard contractual clauses or other lawful mechanisms.

10. Security Measures

The Processor implements technical and organizational measures appropriate to the risk, including access controls, encryption where appropriate, and monitoring of systems.

11. Data Subject Requests

The Processor shall assist the Controller, to the extent reasonably possible, in fulfilling requests from data subjects to exercise their rights under GDPR.

12. Personal Data Breach

In the event of a personal data breach, the Processor shall notify the Controller without undue delay after becoming aware of the breach.

13. Audit Rights

The Controller may audit the Processor’s compliance with this Agreement only where required by law and upon reasonable prior written notice.

Audits shall not unreasonably interfere with the Processor’s business operations.

14. Deletion or Return of Data

Upon termination of the Service, the Processor shall delete or return Personal Data in accordance with the Privacy Policy and applicable law, unless retention is required by law.

15. Liability

Liability under this Agreement is subject to the limitations set forth in the Terms and Conditions. Nothing in this Agreement increases the Processor’s liability beyond what is required by GDPR.

16. Governing Law

This Agreement is governed by the laws of Poland. Any disputes shall be resolved exclusively by the courts of Warsaw, Poland.

17. Order of Precedence

In the event of a conflict between this Agreement and the Terms and Conditions, this Agreement shall prevail with respect to data protection matters only.

18. Contact

For data protection matters, please contact office @ assetpayments.com