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REGISTERLY

📄 Data Processing Agreement (DPA)

Last updated: 25/112025

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This DPA forms part of the Terms of Service between the Customer (“Controller”) and App With Flow (Florent Pottevin) (“Processor”) for the Registerly Service.

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1. Definitions

  • Controller: You, the business using Registerly

  • Processor: App With Flow

  • Personal Data: Any data relating to an identifiable person

  • Processing: Any operation performed on personal data

  • Subprocessors: Third parties used by the Processor

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2. Subject Matter

Registerly processes personal data on behalf of the Controller to provide:

  • Invoicing

  • Client CRM

  • Loyalty features

  • Stock and product management

  • Emailing

  • Analytics

  • AEAT submissions (optional)

  • Device and subscription management

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3. Duration

This DPA remains valid while the Controller uses the Service.

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4. Nature and Purpose of Processing

As described in the Privacy Policy, including storage, transmission, emailing, analytics, and device association.

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5. Types of Data

  • User identity data

  • Client CRM

  • Business data

  • Invoice data

  • Technical device info

  • Login and subscription metadata

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6. Processor Obligations

Processor shall:

  • Process data only on documented instructions

  • Maintain confidentiality

  • Implement appropriate security

  • Notify Controller of data breaches

  • Assist with GDPR rights requests

  • Delete or return data upon termination

  • Keep records of processing operations

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7. Subprocessors

Controller authorizes the use of:

  • Google Firebase (hosting, Firestore, Cloud Functions)

  • RevenueCat (subscription transactions)

  • Google/Apple OS APIs (communications, printing, file storage)

  • AEAT (for Veri*Factu submissions if enabled)

All subprocessors comply with GDPR SCCs or equivalent safeguards.

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8. International Transfers

Transfers may occur to Firebase regions outside the EU. SCCs apply.

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9. Controller Obligations

You agree to:

  • Ensure lawful basis for collecting your clients’ data

  • Not upload illegal or harmful content

  • Respond to data subjects’ rights requests

  • Configure business settings responsibly

  • Manage legal compliance for invoicing and taxation

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10. Security Measures

Processor implements:

  • Firestore security rules

  • HTTPS encryption

  • Hash-chained invoices

  • Device binding

  • Access controls and logs

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11. Breach Notification

Processor will notify Controller without undue delay upon detecting a data breach.

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12. Data Return & Deletion

Upon account deletion, Processor will:

  • Delete user/device/client/product data

  • Anonymize invoices

  • Remove business documents

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