Data Processing Agreement

Last updated: 15 October 2026

This Data Processing Agreement ("DPA") forms part of the NLS Terms of Service (the "Terms") between NLS and the Customer. It applies to personal data that NLS processes on behalf of the Customer in providing the Services ("Customer Personal Data"). Capitalised terms not defined here have the meaning given in the Terms.

On this page

1Roles

The Customer is the controller of Customer Personal Data and NLS is the processor. Where the Customer itself acts as a processor for a third party, NLS acts as a subprocessor and the Customer warrants that its instructions to NLS are authorised by the relevant controller.

2Subject matter and details of processing

Subject matterProvision of the Services under the Terms
DurationThe term of the Terms and the export period after it
Nature and purposeHosting, storing, structuring, analysing and displaying data that the Customer collects through the Services; executing actions the Customer requests on Third-Party Platforms; generating AI Assistant responses
Categories of data subjectsThe Customer's Members; End Users whose clicks and conversions are tracked through the Customer's domains and campaigns; users of advertising accounts the Customer connects
Categories of personal dataMembers: name, email, avatar, activity records. End Users: IP address, approximate location, device, operating system, browser, language, referrer, click identifiers, campaign parameters, conversion events. Advertising accounts: account identifiers, session data, proxy details
Special categoriesNone intended. The Customer must not collect special categories of data through the Services

3Instructions

NLS processes Customer Personal Data only on the Customer's documented instructions, which consist of the Terms, this DPA and the Customer's configuration and use of the Services. NLS will inform the Customer if, in its opinion, an instruction infringes applicable data protection law, and may suspend the processing concerned until the instruction is clarified.

4Confidentiality

NLS ensures that persons authorised to process Customer Personal Data are bound by confidentiality obligations and have access only to the extent needed to provide and support the Services.

5Security

NLS implements technical and organisational measures appropriate to the risk, including: encryption of data in transit; encryption of advertising account session data and proxy credentials at rest; isolation of each Customer's hosted landing pages; role-based access control enforced on the server; two-factor authentication; logging of changes to data and settings; regular backups; and restriction of NLS staff access to Customer Personal Data to support and maintenance purposes.

6Subprocessors

The Customer authorises NLS to engage the subprocessors listed below. NLS will notify the Customer by email or in the Services at least 14 days before adding or replacing a subprocessor. If the Customer objects on reasonable data protection grounds and NLS cannot offer a workable alternative, the Customer may terminate the Terms with respect to the affected Services with a pro rata refund of prepaid fees. NLS imposes on each subprocessor data protection obligations no less protective than those in this DPA and remains responsible for their performance.

SubprocessorLocationPurpose
Hetzner Online GmbHGermanyHosting and storage
Cloudflare, Inc.USA / EU edgeContent delivery, DNS, protection against attacks
Google LLCUSA (EU data centres where available)Service emails, sign-in
Anthropic, PBCUSAAI Assistant responses
OpenAI, L.L.C.USAAI Assistant responses
Google LLC (Gemini)USAAI Assistant responses
TypeSafe AI, Inc.USAAI Assistant responses

Payment processors (Stripe, Plisio) and the sales CRM (Bitrix24) process the Customer's own account and billing data, for which NLS is the controller, and are listed in the Privacy Policy.

7International transfers

Customer Personal Data is stored in Germany. Transfers to subprocessors outside the European Economic Area are made under the European Commission's standard contractual clauses or, where the subprocessor is certified, the EU-US Data Privacy Framework.

8Assistance

Taking into account the nature of the processing, NLS assists the Customer with reasonable measures to respond to data subject requests and to meet the Customer's obligations regarding security, breach notification and data protection impact assessments. NLS will forward to the Customer, without responding itself, any data subject request it receives that relates to Customer Personal Data. NLS may charge a reasonable fee for assistance that goes beyond the standard functions of the Services.

9Personal data breach

NLS will notify the Customer without undue delay, and in any event within 72 hours, after becoming aware of a personal data breach affecting Customer Personal Data, and will provide the information reasonably available to it to help the Customer meet its own notification obligations.

10Audit

On the Customer's written request, no more than once per year, NLS will provide the information reasonably necessary to demonstrate compliance with this DPA, including summaries of relevant third-party reports or certifications where available. If this is insufficient, the Customer may conduct an audit at its own cost, with at least 30 days' notice, during business hours, in a manner that does not disrupt NLS's operations and subject to confidentiality.

11Deletion and return

During the term, the Customer can export Customer Personal Data using the export functions of the Services. After the Terms end, NLS keeps Customer Personal Data available for export for 30 days and then deletes it, except for copies that NLS must retain by law or that remain in backups until overwritten in the ordinary course, in which case they stay protected by this DPA.

12Liability

The liability of each party under this DPA is subject to the exclusions and limitations set out in the Terms.

13Precedence

In case of conflict between this DPA and the Terms regarding the processing of Customer Personal Data, this DPA prevails.

14Contact

Data protection enquiries: abuse@nlscrm.com