Data Processing Addendum (DPA)

Last updated: July 22, 2026

Scope and roles

The customer acts as controller and Firefly Sky SEO acts as processor for customer personal data processed to provide the services, unless applicable law determines otherwise. Processing is limited to documented instructions, the service agreement, and applicable law.

Processing commitments

• Process personal data only for authorized service purposes.
• Ensure persons handling data are subject to confidentiality obligations.
• Maintain appropriate technical and organizational security measures.
• Use subprocessors under written obligations that provide appropriate protection.
• Assist customers, where reasonably possible, with data-subject requests, security incidents, impact assessments, and regulatory consultations.
• Delete or return customer personal data at the end of services, subject to legal retention requirements.

International transfers

Where required, transfers may be supported by an adequacy decision, Standard Contractual Clauses, or another legally recognized transfer mechanism.

Audits and information

We will make information reasonably necessary to demonstrate compliance available subject to confidentiality, security, proportionality, and agreed commercial terms.

Request the DPA

To request the applicable DPA or discuss data-processing requirements, email support@fireflysky.net with the subject “DPA Request.”