LEGAL

Data Processing Agreement

Processor terms where the provider processes personal data on behalf of business customers.

REZERV.mk · PROCES IN DOOEL

1. Parties and scope

This Data Processing Agreement forms part of the applicable REZERV.mk service agreement between the business customer as Controller and PROCES IN DOOEL as Processor, to the extent PROCES IN DOOEL processes personal data on behalf of that customer.

Where PROCES IN DOOEL independently determines processing purposes and means for its own account, billing, security or business administration, it acts as a separate Controller for that processing.

2. Processing instructions

The Processor shall process personal data only on documented lawful instructions from the Controller, except where otherwise required by applicable law.

The Processor shall inform the Controller where an instruction appears to conflict with applicable data protection law, to the extent legally required.

3. Subject matter and purpose

Processing supports the provision, administration, security, maintenance and support of the REZERV.mk service.

The specific categories of data, data subjects, processing activities and duration must be described in the applicable DPA annex and reflect actual enabled functionality.

4. Confidentiality

Persons authorized to process personal data must be subject to appropriate confidentiality obligations.

5. Security measures

The Processor shall implement technical and organizational measures appropriate to the risks of the processing, including relevant access controls, tenant separation, confidentiality, integrity, availability, recovery and security monitoring measures.

The final security annex must describe actual implemented safeguards and must not claim unverified certifications or capabilities.

6. Subprocessors

The Controller grants general authorization for appropriately vetted subprocessors subject to applicable contractual safeguards.

The Processor shall provide notice of material subprocessor changes and an appropriate opportunity for justified objection in accordance with the approved procedure and applicable law.

7. Personal data breaches

The Processor shall notify the Controller without undue delay and no later than 24 hours after becoming aware of a personal data breach affecting Controller personal data.

Initial notice may be supplemented as investigation progresses.

The parties remain responsible for their respective statutory notification and cooperation obligations.

8. Data subject requests

The Processor shall reasonably assist the Controller in responding to lawful data subject requests.

Requests received directly concerning Controller-managed data will be forwarded without undue delay, normally within two working days or sooner where necessary.

9. International transfers

Transfers outside the applicable protected jurisdiction must be supported by appropriate legal mechanisms and safeguards where required.

The actual countries, recipients and transfer mechanisms must be documented.

10. Audit and compliance

The Processor shall provide information reasonably necessary to demonstrate compliance with its processor obligations.

Audits must be proportionate, appropriately scoped, confidential and conducted without unnecessary exposure of other customers' information or infrastructure security.

11. Return and deletion

Following termination of the applicable service, Controller data will be handled according to the approved 90-day controlled export/reactivation period, applicable legal obligations and the agreed deletion procedure.

Retention beyond that period must have an appropriate legal or contractual justification.

Backup copies are subject to restricted access, appropriate retention controls and deletion through the applicable backup lifecycle.

12. Assistance and cooperation

The Processor shall provide reasonable assistance concerning security, breach investigation, data protection assessments and regulatory enquiries, taking into account the nature of processing and information available to it.

13. Liability and governing terms

Liability and remedies are governed by the applicable agreement and mandatory data protection law.

This DPA does not eliminate statutory rights or responsibilities that cannot legally be excluded.

14. Required annexes

Before legal approval, complete and verify:

  • Annex A — Processing Description: categories of data subjects, categories of personal data, purposes, processing operations and duration.
  • Annex B — Technical and Organizational Measures: actual implemented safeguards.
  • Annex C — Subprocessors and International Transfers: actual providers, processing locations, safeguards and applicable transfer mechanisms.

PROCES IN DOOEL
PROCES IN DOOEL
Tax Identification Number МК4004002122057
Bank Account: 210-0570712901-29
Skopje
Macedonia
contact@rezerv.mk
+389 71 244 660

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