Data Processing Agreement

Last updated: March 2026

This Data Processing Agreement ("DPA") supplements the Terms of Service between you ("Controller") and Nubes Lunae, operating CatalogCompass ("Processor"). It governs the processing of personal data by the Processor on behalf of the Controller, in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1. Scope of Processing

  • Subject matter: Providing the CatalogCompass PIM platform as described in the Terms of Service.
  • Nature: Storage, retrieval, transformation, and synchronization of product catalog data.
  • Types of personal data: Names, email addresses (account data); product descriptions and metadata.
  • Categories of data subjects: Controller's employees, customers referenced in product data.

2. Processor Obligations

  • Process personal data only on documented instructions from the Controller.
  • Ensure persons authorized to process personal data have committed to confidentiality.
  • Implement appropriate technical and organizational measures to ensure security of processing.
  • Engage sub-processors only with prior authorization; maintain an up-to-date list.
  • Assist the Controller in responding to data subject requests.
  • Delete or return all personal data upon termination of the agreement.
  • Make available all information necessary to demonstrate compliance; allow for audits.
  • Notify the Controller of a personal data breach without undue delay (within 72 hours).

3. Security Measures

  • Data at rest: AES-256 encryption on Azure PostgreSQL and Cloudflare R2.
  • Data in transit: TLS 1.2+ for all connections.
  • Access control: Role-based access with per-organization tenant isolation.
  • Backups: Automated daily backups with 7-day retention.

4. Sub-Processors

The Controller authorizes the use of sub-processors listed on our Sub-Processors page. The Processor will notify the Controller of any intended changes to sub-processors at least 30 days in advance. View current sub-processors

5. Contact

For DPA-related inquiries, contact us at [email protected].