1. Parties and application
This data processing agreement applies between the shop that uses Repairflow (the controller) and Repairflow (the processor). It forms part of our terms and conditions and applies automatically as soon as the shop puts personal data of its customers into the service. A separate signature is not needed; the shop can save or print this page for its own records.
Terms such as personal data, processing, data subject and personal data breach have the meaning given to them in the General Data Protection Regulation (GDPR).
2. What it is about
Subject matter and purpose. Repairflow processes personal data on behalf of the shop for one purpose: providing the service with which the shop keeps track of its repairs, customers, point of sale, invoices and calendar, as described on our website.
Types of data. Name, address, telephone numbers, email address, date of birth, business details and notes about customers; device details such as brand, model, serial number, IMEI and access code; photos of devices; signatures with time and IP address; repair history; receipts, invoices, quotes and payments; appointments; login details and messages of the customer portal; emails that the shop sends to customers through the service.
Data subjects. Customers of the shop, the contact persons of business customers, and the employees of the shop as regards what the shop records about them, such as shifts and leave.
Duration. For as long as the contract between the shop and Repairflow runs, plus the deletion period from article 9.
3. Instructions
Repairflow processes the data only on the basis of the shop’s instructions. Those instructions are: this agreement, the terms and conditions and the choices the shop makes in the service, such as which emails are sent automatically, whether the customer portal is switched on and which data a customer sees in it.
Repairflow does not process the data for its own purposes, does not look at them beyond what is necessary for administration, security or a support request from the shop, and does not give them to third parties, unless a law requires it. In that case Repairflow informs the shop in advance, unless the law prohibits this.
If Repairflow considers that an instruction infringes the GDPR, it informs the shop.
4. Responsibilities of the shop
The shop is responsible for the lawfulness of the processing: that it has a legal basis for the data it records, that it informs its customers, that it records no more than necessary and that it deletes data it no longer needs. The shop itself decides which of its employees are given access and keeps that access up to date.
Access codes of devices are sensitive. The shop records them only if that is necessary for the repair and deletes them afterwards.
5. Confidentiality and staff
Everyone at Repairflow who has access to the data is bound by confidentiality and has access only to the extent necessary for their work.
6. Security
Repairflow takes appropriate technical and organisational measures to protect the data against loss and unlawful processing. At present these include at least:
- encrypted connections (TLS) between users, the service and the database;
- encrypted storage at the database service and the file storage;
- passwords stored only in hashed form; connections with other services stored encrypted;
- separation of data per shop in the software, so that a shop never sees data of another shop;
- roles and rights per user, to be set by the shop itself;
- a daily backup, kept for thirty days, with a tested recovery path;
- monitoring with alarms, logs and limiting of the number of login attempts;
- access to production data limited to those who need it.
Repairflow may adjust these measures as long as the level of protection does not decrease.
7. Sub-processors
The shop gives Repairflow permission to engage the following sub-processors:
| Sub-processor | Processing | Establishment and transfer |
|---|---|---|
| Amazon Web Services EMEA SARL | Servers, file storage for photos and logos, backups, logs, sending email | Ireland (region eu-west-1); data remain in the European Union |
| MongoDB Limited | The database | European Union |
| OpenAI | AI features: improving a text in a repair, only the text entered for that purpose, only if the shop uses the feature | United States, on the basis of the European Commission’s standard contractual clauses |
OpenAI does not use these data to train models and keeps them for a maximum of 30 days.
Repairflow concludes arrangements with each sub-processor that are at least as strict as this agreement and remains responsible towards the shop for what a sub-processor does.
If Repairflow wishes to add or replace a sub-processor, it informs the shop by email at least thirty days in advance. If the shop has a well-founded objection, the parties consult each other; if they cannot reach agreement, the shop can terminate the contract with effect from the date on which the change takes effect.
Services that the shop itself connects to Repairflow, such as a payment service or a wholesaler, are not sub-processors of Repairflow. For those, the shop concludes its own agreement with that provider.
8. Personal data breaches
If Repairflow discovers a security breach affecting personal data of the shop, it reports this to the shop without undue delay and no later than 48 hours after discovery, at the email address of the account. The report contains what is known about the nature of the breach, the data and data subjects concerned, the likely consequences and the measures taken, and is supplemented as soon as more is known.
The shop decides whether it reports the breach to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) and to the data subjects. Repairflow helps it with the information it has.
9. Return and deletion
During the contract the shop can itself view and edit its data in the service, and can ask Repairflow for a copy in a common file format.
After the end of the contract the shop can still ask for such a copy for 30 days. After that, Repairflow deletes all personal data of the shop from the service within 30 days, so no later than 60 days after the end. Backups that still contain the data are automatically deleted 30 days after that. Data that Repairflow is legally required to keep, such as the invoices for the subscription, are retained for as long as the law prescribes.
10. Assistance with data subjects’ rights and supervision
If a customer of the shop requests access, correction, deletion or transfer, the shop handles it. The service provides the means for this: viewing, changing and deleting data; we make a copy of the data of a single customer on request. If a request reaches Repairflow directly, Repairflow forwards it to the shop without responding to its substance.
Repairflow assists the shop, as far as can reasonably be expected, with a data protection impact assessment, with prior consultation of the supervisory authority and with questions from the supervisory authority.
11. Audit
The shop may check once a year, and additionally whenever there is a specific reason to do so, whether Repairflow complies with this agreement. For this purpose Repairflow first answers written questions and provides available documentation. If that does not satisfy the need for an audit, an independent expert bound by confidentiality may carry out an audit, announced at least thirty days in advance, during office hours and without disrupting the service for other shops. The shop bears the costs of the audit, unless it reveals a material failure on the part of Repairflow.
12. Liability and other provisions
For liability under this agreement the limitations from the terms and conditions apply, to the extent the GDPR permits. Each party bears the fines that a supervisory authority imposes on it for its own failures.
In the event of conflict, this agreement takes precedence over the terms and conditions, but only insofar as the processing of personal data is concerned. Repairflow announces changes to this agreement at least thirty days in advance, in the same way as changes to the terms and conditions. Dutch law applies to this agreement.