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Data Processing Agreement (DPA)

GDPR-compliant template. Last updated: 2026-09-24

This Data Processing Agreement (the "DPA") forms an integral part of the Terms of Use of Sentinel Briefing and applies whenever Sentinel Briefing (the "processor") processes personal data on behalf of the Customer (the "controller").

1. Definitions

Terms used in this DPA follow the definitions of the General Data Protection Regulation (EU 2016/679, GDPR): "personal data", "processing", "controller", "processor", "data subject", "personal data breach".

2. Subject matter and purposes of the processing

The processor processes data to provide the strategic monitoring service: collecting the sources chosen by the Customer, sorting and analysing articles with artificial intelligence, writing and sending briefings, checking the facts they cite, managing users and access, and billing.

3. Categories of data and data subjects

CategoryDataData subjects
Identification first name, last name, email address, internal identifier the Customer's users
Sign-in authentication logs, IP address, browser, session cookie the Customer's users
Content watches, sources, briefings, team comments, feedback on briefings the Customer's users
Activity log actions of the firm's members (sign-ins, invitations, role changes, API keys, exports) the Customer's users
Analysed sources names, positions, organisations and quotations found in the articles and public registers monitored people mentioned in the sources
Billing plan, subscription status, Stripe identifiers (no card data) the Customer's billing contact

4. Duration of the processing

Processing lasts for as long as the Customer's account is open. The end of a paid subscription does not close the account, which returns to the free plan. When the account is closed, the Customer may request an export of its data for 30 days; its data, including personal data, is deleted or anonymised no later than 90 days after closure. Articles collected from public sources are kept for the history of the watches.

5. Sub-processors

The processor uses sub-processors, under a data processing agreement with each of them, in the following categories:

CategoryLocation
Hosting, backups and email sendingGermany (EU)
Artificial intelligence modelsEU and United States
Web search and fact checkingUnited States
Audio transcriptionUnited States
PaymentEU and United States
Audience measurement, after consentEU

The list of sub-processors by name is annexed to the signed DPA and provided on request at contact@sentinelbriefing.com. For transfers to the United States, safeguards rely on the standard contractual clauses adopted by the European Commission (Article 46(2)(c) GDPR) or, where the recipient has joined it, on the EU-US Data Privacy Framework. The Customer is informed in advance of any change to this list and may object within 30 days.

6. Security measures

  • TLS encryption of all communications, HSTS with preload
  • HttpOnly, Secure and SameSite=Lax session cookies
  • Content Security Policy (CSP)
  • Data isolation between firms, checked by automated tests
  • Rate limiting on sensitive endpoints and the public API
  • Structured logs and error monitoring hosted by the processor
  • Daily encrypted database backups, with an off-site copy
  • Firm activity log, available to the firm's administrators
  • Sign-in through the organisation's identity provider (SSO) on request
  • Data deleted no later than 90 days after the account is closed

7. Data subjects' rights

The Customer can exercise its users' GDPR rights directly from the application:

  • Article 15 (access) and Article 20 (portability): GET /api/me/export returns a complete JSON file
  • Article 17 (erasure): DELETE /api/me anonymises the account immediately
  • Article 7 (consent): consent banner on the first visit, refusal in one click
  • Article 16 (rectification): from the account settings

8. Breach notification

In the event of a personal data breach, the processor informs the Customer within 72 hours, in line with Article 33 GDPR, by email to the account's contact address.

9. Audit

On reasonable request and with 30 days' notice, the Customer may ask for a certificate of compliance or an audit limited to the technical and organisational measures applicable to its data.

10. DPO / GDPR contact

For any question about data protection: contact@sentinelbriefing.com

A signable version is available on request at the address above. For the Team, Firm and Enterprise plans, a custom DPA can be negotiated.