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// Legal
Last updated: 12 June 2026
Draft / Template
This document is a template/draft. It must be reviewed and approved by a qualified solicitor, and all bracketed placeholders completed, before it goes live.
This Data Processing Agreement ("DPA") forms part of the Terms of Service between Essenzi Media Ltd (company number 16144272, registered office Capital Tower Business Centre, 3rd Floor, Capital Tower, Greyfriars Road, Cardiff, CF10 3AG, United Kingdom) ("Processor", "we") and the business customer ("Controller", "you") where, in using the Service, you provide personal data relating to third parties for us to process on your behalf. It is entered into pursuant to Article 28 of the UK GDPR and the EU GDPR. Where there is a conflict, this DPA prevails on data-protection matters. Capitalised terms not defined here have the meaning given in the GDPR.
Types of personal data (to the extent the Controller chooses to submit them): names, contact details, images/video/PDF content, social-media handles or website URLs, and any personal data contained in campaign briefs or uploaded media. The Controller must not submit special-category data.
Categories of data subjects: the Controller's personnel and authorised users, and any individuals featured in or connected with the Controller's campaign materials or submitted content.
We will:
The Controller provides general authorisation for us to engage the following sub-processors, subject to flow-down of equivalent data-protection obligations under a written contract:
We will inform the Controller of any intended changes concerning the addition or replacement of sub-processors, giving the Controller the opportunity to object on reasonable data-protection grounds. We remain liable to the Controller for the performance of our sub-processors' obligations.
Taking into account the state of the art and the risks of processing, we implement appropriate technical and organisational measures, including: encryption of data in transit (HTTPS/TLS); one-way hashing of passwords (bcrypt) and encryption of 2FA secrets; HttpOnly session cookies; access controls and least-privilege principles; server-side secret management; logging and monitoring; rate limiting and abuse prevention; and use of reputable infrastructure providers. Measures are reviewed and updated as appropriate. [Detailed measures to be confirmed and may be set out in an annex.]
Where processing involves transfers of personal data outside the UK / EEA (including to US-based sub-processors such as Anthropic, Stripe, Cloudflare and Google), such transfers are made under an appropriate transfer mechanism — the European Commission's Standard Contractual Clauses (SCCs), the UK International Data Transfer Agreement (IDTA) or UK Addendum, or reliance on an applicable adequacy decision — together with any supplementary measures required.
We will notify the Controller without undue delay, and in any event within 72 hours, after becoming aware of a personal data breach affecting personal data processed on the Controller's behalf, and will provide the information reasonably required to enable the Controller to meet its own notification obligations under the GDPR.
We will make available to the Controller information necessary to demonstrate compliance with Article 28 and allow for and contribute to audits, including inspections, conducted by the Controller or an auditor it mandates. Audits will take place on reasonable prior written notice, no more than once per year (save where required following a breach or by a supervisory authority), during business hours, subject to confidentiality, and so as to minimise disruption to the Service.
On termination or expiry of the Service, and at the Controller's choice, we will delete or return all personal data processed on the Controller's behalf and delete existing copies, unless retention is required by law. Note that raw DNA-extraction content is processed transiently and not stored.
Each party's liability under or in connection with this DPA is subject to the limitations and exclusions of liability set out in the Terms of Service, except to the extent such limitation is not permitted by applicable data-protection law. Nothing in this DPA limits any liability that cannot be limited or excluded by law.
For matters arising under this DPA, contact our privacy contact / DPO at studio@houseofessenzi.com, or Essenzi Media Ltd at studio@houseofessenzi.com. To execute a counter-signed copy of this DPA, contact us.