Data processing agreement
Last updated 19 October 2026
This agreement is part of the Terms of service. It applies whenever PingPong handles personal data on behalf of a client, as required by Article 28 of the GDPR.
1. Parties and roles
The client is the controller of the personal data it puts into its workspace. Corné Romme, trading as PingPong (eenmanszaak in Zeewolde, the Netherlands, KvK 78635969, VAT NL003358084B92), is the processor.
2. Subject, nature and duration
PingPong processes personal data only to provide the design and development subscription: hosting the workspace, doing the tasks the client asks for, and sending the related emails. Processing lasts as long as the client has a workspace, plus the deletion period in section 9.
3. Types of data and people
| People | Data |
|---|---|
| The client's team members | Name, email address, profile photo, sign-in details, comments and activity in the workspace |
| The client's own customers, users or contacts | Whatever the client includes in tasks, files, the brief or website content, for example names, email addresses or photos |
The client should not put special categories of data (such as health data) in the workspace unless agreed in writing first.
4. Instructions
PingPong processes the data only on the client's documented instructions. The Terms, this agreement and the tasks the client adds in the workspace are those instructions. If PingPong believes an instruction breaks the GDPR, Corné will tell the client right away. If the law requires processing anyway, PingPong will say so first unless the law forbids that.
5. Confidentiality and security
Only Corné has access to client data. Anyone else who ever gets access is bound to confidentiality. PingPong takes appropriate measures, including:
- data stored and hosted in the EU (Ireland), encrypted in transit and at rest
- private file storage, with files served only to people in the workspace
- passwords, sign-in links and invite links stored only as hashes
- card and bank details held by Stripe, never by PingPong
- access to the hosting accounts protected with two-step sign-in
6. Sub-processors
The client gives general permission for PingPong to use these sub-processors:
| Sub-processor | What for | Where |
|---|---|---|
| Supabase | Database, sign-in and file storage | EU (Ireland) |
| Vercel | Hosting the app | EU (Ireland), with a global network |
| Stripe | Payments and invoices | EU and US |
| Resend | Sending emails | US |
| Google sign-in and email | EU and US | |
| Cloudflare | Domain and network | Global |
| Anthropic (Claude) | Software used for design and code work, without training on client data | US |
| OpenAI (ChatGPT) | Software used for design and code work, without training on client data | US |
PingPong will tell the client at least 30 days before adding or replacing a sub-processor. The client can object on reasonable grounds; if no solution is found, the client can end the subscription without extra cost. PingPong makes sure each sub-processor is bound by the same data protection duties and stays responsible for them.
7. Helping the client
PingPong helps the client, as far as reasonably possible, to answer requests from people who use their GDPR rights (access, correction, deletion and so on), and with security, data protection impact assessments and questions from the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
8. Data breaches
If PingPong finds a personal data breach that affects the client's data, Corné will tell the client without undue delay and within 48 hours. The notice says what happened, which data and people are affected, the likely consequences and what is being done about it, so the client can meet its own 72-hour duty.
9. End of the agreement
When the subscription ends, the workspace stays available read-only for 3 months so the client can download its files. After that PingPong deletes the client's personal data, unless the law requires keeping it (for example invoices, which Dutch tax law requires keeping for 7 years). Backups are overwritten in their normal cycle. The client can ask for deletion sooner.
10. Audits
PingPong gives the client the information needed to show it meets this agreement. The client may have an audit done by an independent auditor bound to confidentiality, with at least 30 days' notice, at most once a year unless there was a breach. The client pays for the audit.
11. Transfers outside the EU
Where a sub-processor handles data outside the EU, PingPong makes sure the transfer is protected, through the EU-US Data Privacy Framework or the European Commission's Standard Contractual Clauses.
12. Liability and other terms
Liability under this agreement follows the limits in the Terms of service. Dutch law applies, and disputes go to the court in the district where PingPong is based. If this agreement and the Terms conflict on data protection, this agreement wins.