Data Processing Agreement (Annex A)

About this document

1. Basis. Part 1 reproduces the Standard Contractual Clauses between controllers and processors adopted by the European Commission in Implementing Decision (EU) 2021/915 of 4 June 2021 (OJ L 199, 7.6.2021, p. 18; CELEX 32021D0915). The text was taken from the official English version published by the Publications Office of the EU (publications.europa.eu/resource/celex/32021D0915, retrieved on 4 October 2026).

2. Options chosen. Where the official text offers a choice, Part 1 shows the option chosen:

• Clause 1(a), 8(c)(4), 9 and 9.1–9.2: the options for Regulation (EU) 2016/679 (GDPR). References to Regulation (EU) 2018/1725, which applies only to EU institutions, are omitted throughout.
• Clause 5 (optional docking clause): not used.
• Clause 7.7(a): Option 2, general written authorisation, with a notice period of 30 days.
• Clause 9.1(a): "unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons".

No other word of the Clauses has been changed (Clause 2(a)).

3. Parties. In Part 1, "the controller" is the School and "the processor" is ntagks, both identified in Annex I. Capitalised terms not defined here have the meaning given in the School Agreement.

4. Scope. This DPA covers Classroom Data only: the personal data that ntagks processes on the School's behalf to provide the Classroom (Annex II). It does not cover:

• each individual's own Learner Account, for which ntagks is an independent controller under its Privacy Policy; or
• the Shared Progress Data that the Classroom shows to Teachers and Owners, for which the School and ntagks are joint controllers under Annex B of the School Agreement.

5. Structure. Part 1: the Clauses (Sections I–III). Part 2: supplementary terms, added under Clause 2(b), which do not contradict the Clauses. Annexes I–IV complete the Clauses.

Part 1: Standard Contractual Clauses

SECTION I

Clause 1: Purpose and scope

(a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

(b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679.

(c) These Clauses apply to the processing of personal data as specified in Annex II.

(d) Annexes I to IV are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679.

Clause 2: Invariability of the Clauses

(a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3: Interpretation

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4: Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5: Docking clause (optional)

Not used.

SECTION II: Obligations of the parties

Clause 6: Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7: Obligations of the Parties

7.1 Instructions

(a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 or the applicable Union or Member State data protection provisions.

7.2 Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3 Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4 Security of processing

(a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5 Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

7.6 Documentation and compliance

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7 Use of sub-processors

(a) GENERAL WRITTEN AUTHORISATION: The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 30 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679.

(c) At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

(e) The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8 International transfers

(a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8: Assistance to the controller

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions

(c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

(1) the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;

(2) the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;

(3) the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;

(4) the obligations in Article 32 of Regulation (EU) 2016/679.

(d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9: Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons;

(b) in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller’s notification, and must at least include:

(1) the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;

(2) the likely consequences of the personal data breach;

(3) the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c) in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III: Final provisions

Clause 10: Non-compliance with the Clauses and termination

(a) Without prejudice to any provisions of Regulation (EU) 2016/679, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

(1) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;

(2) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679;

(3) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679.

(c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

(d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

Part 2: Supplementary terms

These terms are added under Clause 2(b). They give procedures and additional safeguards. They are read subject to Part 1: if anything in Part 2 contradicts Part 1, Part 1 prevails (Clause 4). Nothing in Part 2 limits the rights of data subjects.

B1. Relationship with the School Agreement

B1.1 This DPA is Annex A to the School Agreement between the School and ntagks and forms part of it. "Controller" means the School; "processor" means ntagks.

B1.2 ntagks sets the terms of this DPA as part of a standard service. The School, as controller, keeps the final say over the processing of Classroom Data through its instructions (B2), its right to object to sub-processors (B3), and its rights to suspend and terminate (Clause 10 and clause 26 of the School Agreement). Changes follow B12.

B2. Documented instructions (Clause 7.1)

B2.1 The controller's documented instructions are:

• (a) the School Agreement and this DPA;
• (b) the School's use of the Classroom's functions: each invitation, class, assignment, removal, Minute Pack allocation and setting made by an Owner or Teacher is an instruction to process the data concerned accordingly;
• (c) written instructions sent by an Owner to hello@certifyboost.com, which ntagks confirms in writing.

B2.2 If an instruction under B2.1(c) would require functionality that the Service does not offer, ntagks tells the School and, where it cannot follow the instruction, Clause 10(a) applies.

B3. Sub-processors (Clause 7.7)

B3.1 Agreed list. The agreed list of sub-processors is Part A of Annex IV.

B3.2 Notice of changes. ntagks informs the School of any intended addition or replacement at least 30 days before the new sub-processor starts processing Classroom Data. ntagks does so by e-mail to every Owner and by a notice in the Classroom. The notice states the sub-processor's name and location, what it will do, and the transfer safeguard, if any.

B3.3 Objection. The School may object in writing within those 30 days, giving its reasons relating to data protection. ntagks then works with the School in good faith to address the objection. If that is not possible before the change, the School may terminate the School Agreement with effect before the new sub-processor starts processing, and receives a pro-rata refund of prepaid Fees for the unused part of the Term (clauses 26.1(c) and 26.4 of the School Agreement).

B3.4 Sub-processor contracts. ntagks's contracts with its sub-processors are the providers' standard data processing agreements. On request, ntagks provides the School with a copy or a link (Clause 7.7(c)).

B4. Personal data breaches (Clause 9)

B4.1 ntagks notifies the School of a personal data breach concerning Classroom Data without undue delay, and in any event within 48 hours after becoming aware of it. ntagks e-mails every Owner and the contact in Annex I, and phones the contact where the breach is serious.

B4.2 In addition to the content required by Clause 9.2, the notification states, as far as known: when and how the breach was discovered; which Schools and which categories of Classroom Data are affected; whether minors are affected; and what the School may need to do (for example, tell its Teachers to change passwords). ntagks updates the School as new information becomes available.

B4.3 ntagks documents every personal data breach concerning Classroom Data, including the facts, effects and remedial action, and gives the School a copy of the record for its breaches.

B4.4 ntagks does not notify the supervisory authority or data subjects of a breach of Classroom Data on the School's behalf unless the School instructs it to. Where the same incident also affects Learner Accounts or Shared Progress Data, ntagks makes its own notifications as controller and coordinates with the School under Annex B.

B5. Requests from data subjects (Clause 8(a) and (b))

B5.1 ntagks forwards to the School, within 3 Business Days, any request it receives that concerns Classroom Data. The School authorises ntagks to acknowledge receipt and to tell the person that the request has been passed to the School.

B5.2 Standing authorisations. Under Clause 8(a), the School authorises ntagks to give effect, without consulting the School first, to the following requests:

• (a) when a Student, Teacher or Owner deletes their own Learner Account, ntagks also deletes their Classroom Data (membership, invitations, assignment links and their place in Minute Pack allocations) as part of the account deletion;
• (b) when an invited person declines an invitation, ntagks records the decline;
• (c) when a person who never created an account asks ntagks to delete their e-mail address from an unanswered invitation, ntagks deletes the invitation and tells the School.

B5.3 Self-service. Teachers and Owners can correct a Student's class, remove Students and revoke invitations in the Classroom.

B5.4 Copies. At the School's request, for example to answer an access request from a Student or a parent, ntagks provides a copy of a named person's Classroom Data in a machine-readable format within 10 Business Days.

B6. Other assistance (Clause 8(c))

B6.1 For a data protection impact assessment or a prior consultation, ntagks provides, on request, the description of the processing (Annex II), the measures (Annex III), the sub-processors (Annex IV) and the relevant parts of its own risk assessment of the platform.

B6.2 Reasonable assistance is free of charge. For requests that are manifestly excessive or repetitive, ntagks may ask for reasonable costs, agreed with the School in advance.

B7. Information and audits (Clause 7.6)

B7.1 Information first. ntagks answers the School's reasonable written questions about the processing, including security questionnaires, within 30 days, and provides Annex III documentation and, where available, its sub-processors' certifications or audit reports.

B7.2 Audits and inspections. If the information is not enough, the School may audit, itself or through an independent auditor:

• on at least 30 days' written notice, or shorter notice where there are indications of non-compliance or a supervisory authority requires it;
• during Business Days and normal working hours;
• at most once in any 12 months, unless there are indications of non-compliance or a supervisory authority requires it;
• by an auditor bound by confidentiality who is not a competitor of ntagks;
• without access to data of other customers or to information that would compromise the security of the Service.

B7.3 ntagks has no data centre of its own. Classroom Data is hosted by the sub-processors in Annex IV in their own facilities, which are covered by their certifications and reports. Inspections of premises therefore concern ntagks's place of business, by appointment.

B7.4 Each party bears its own costs of an audit.

B8. Return and deletion (Clause 10(d))

B8.1 When the School Agreement ends, the School may choose, by e-mail within 30 days after the end, to receive a copy of the Classroom Data before deletion. The copy is in CSV or JSON and contains the roster and invitations (names, e-mail addresses, status, class), the classes, the assignments, and the assignment progress as shown in the Classroom on the last day.

B8.2 ntagks deletes the Classroom Data no later than 30 days after the end, after sending any copy requested. Deleted data disappears from backups within a further 7 days. ntagks certifies the deletion in writing on request. If the School makes no choice, ntagks deletes.

B8.3 The following are not Classroom Data and are not deleted under B8.2:

• each person's Learner Account and their own learning data, including the source data from which the Shared Progress Data was shown, which each person keeps or deletes themselves (ntagks is an independent controller for them);
• Live Interview Minutes already credited to Students;
• ntagks's own billing, tax and accounting records about the School, kept as the law requires;
• statistics that identify no person and no School.

B8.4 During the term. The record of a removed Student stays in the School Account while the School Agreement lasts, because it holds the Seat during the Cooldown and lets the School re-invite the Student. At the School's request, ntagks deletes the records of Students removed more than 14 days earlier within 30 days.

B9. Personnel

B9.1 ntagks is a sole proprietorship. Access to Classroom Data in production is limited to the proprietor. Any employee or contractor who is given access in future will first commit in writing to confidentiality and receive data protection instructions.

B10. Location of processing and transfers (Clause 7.8)

B10.1 Classroom Data is stored in the European Union (Supabase database and storage on Amazon Web Services in Dublin, Ireland).

B10.2 Personal data is transferred outside the EEA only to the sub-processors in Part A of Annex IV, on the basis shown there: an adequacy decision (the EU-US Data Privacy Framework, Commission Implementing Decision (EU) 2023/1795) for certified US recipients, and otherwise, or as a fallback, the Standard Contractual Clauses of Commission Implementing Decision (EU) 2021/914 (Module 3, processor to processor).

B10.3 If an authority asks ntagks or a sub-processor for Classroom Data, ntagks tells the School unless the law forbids it, and discloses only what it is legally required to disclose.

B10.4

B11. Liability

B11.1 The liability rules of clause 24 of the School Agreement apply to this DPA. They do not limit any liability towards data subjects under Article 82 GDPR.

B12. Duration and changes

B12.1 This DPA applies for as long as ntagks processes Classroom Data, including after the School Agreement ends until the data is deleted or returned.

B12.2 Part A of Annex IV changes only under B3. ntagks may update Annex III to reflect new measures, provided the overall level of protection is not reduced; it tells the School of material updates.

B12.3 Any other change to Part 2 or the Annexes follows clause 29 of the School Agreement: 30 days' notice and, for a change that is materially adverse to the School, the right to terminate before it takes effect. Part 1 cannot be changed (Clause 2(a)).

B13. Governing law and courts

This DPA is governed by Greek law. The courts of Thessaloniki, Greece, have exclusive jurisdiction over disputes between the parties. This does not affect the rights of data subjects to bring proceedings or complaints under the GDPR.

Annex I: List of parties

Controller: the School

Processor: ntagks

Annex II: Description of the processing

Categories of data subjects whose personal data is processed

1. Students: learners whom the School invites to, or who are members of, its School Account. They are at least the Minimum Age (15, or 16 in DE, NL, IE, PL, RO, LU, HU, SK, HR and LI), and many are under 18.
2. Invitees: people whose e-mail address the School has entered in an invitation but who have not yet created an account or answered.
3. Teachers and Owners: the School's staff or representatives who have the role "moderator" (Teacher) or "owner" in the School Account.

Categories of personal data processed

Sensitive data processed (if applicable) and applied restrictions or safeguards

None intended. The Classroom has no field for special categories of data. The School must not enter special categories of data or data about criminal offences into free-text fields such as class names or assignment titles (clause 15.1(f) of the School Agreement). Because many Students are minors, the safeguards in Annex III apply to all Classroom Data: access only by the School's own Teachers and Owners after a server-side check, no Classroom Data visible to other Students, and no use for any other purpose.

Nature of the processing

Collection (from the School's entries and from Students' responses to invitations), recording, organisation, storage, retrieval, combination with the Learner Account for display, consultation by the School's Teachers and Owners, transmission by e-mail (invitations and assignment notifications), restriction, and erasure, in a hosted web application.

Purpose(s) for which the personal data is processed on behalf of the controller

1. Letting the School invite Students, manage its roster and organise Students into classes.
2. Letting Teachers set assignments and showing them to the Students concerned, including in-app and e-mail notifications.
3. Giving the School's Teachers and Owners the Classroom's dashboard and lists.
4. Letting Owners allocate Live Interview Minutes to selected Students.

4a. Letting Students ask their Teachers to review an AI score, and Teachers answer them in the App.

5. Administering the access of the School's Teachers and Owners.
6. Keeping the Classroom secure and preventing abuse (rate limits, authorisation checks, logs).
7. Providing support at the School's request.

Duration of the processing

For the term of the School Agreement, and afterwards until deletion or return under Part 2, B8: deletion no later than 30 days after the end, and removal from backups within a further 7 days. Technical logs are kept by the hosting providers for a few days. Delivery logs of e-mails are kept by Resend for 30 days.

For processing by (sub-)processors, also specify subject matter, nature and duration of the processing

See Annex IV, Part A. Each sub-processor processes Classroom Data only for the activity described there, for the duration above.

Annex III: Technical and organisational measures

These measures describe the Service as built on 4 October 2026.

Measures of pseudonymisation and encryption

• All connections to the App use TLS. Both web applications send HTTP Strict Transport Security.
• Data at rest is encrypted by the database and storage provider (Supabase on Amazon Web Services).
• Records are keyed by random identifiers (UUIDs). The profile table holds no e-mail address; e-mail addresses live in the authentication system and, for invitations, in the membership record.
• Classmates see each other on rankings only under a random two-word handle, never by name.

Measures for ensuring ongoing confidentiality, integrity, availability and resilience

• Managed PostgreSQL database (Supabase) with row-level security enabled on every table.
• Development and production run on separate Supabase projects; the production project is in its own Supabase organisation. Production data is not copied to development.
• Database changes reach production only as versioned migration files, through an automated release pipeline that first runs linting, type checks and a dry run of the migration against production.
• Per-user rate limits on every abuse-relevant endpoint, backed by a database counter that works across all server instances. Classroom limits: invitation batches 20 per hour (the check fails closed if the limiter is unavailable), other Classroom writes 60 per hour, billing sessions 10 per hour. An invitation batch cannot exceed the free Seats, and a Minute Pack purchase is limited to 200 Students.

Measures for ensuring the ability to restore availability and access in a timely manner

• Daily database backups by Supabase, kept for 7 days.
• The full database schema can be rebuilt from the migration files in the code repository.

Processes for regularly testing, assessing and evaluating effectiveness

• Automated checks on every release (linting, type checks, migration dry run).
• Review of the database provider's security and performance advisors, kept clean except for documented, intentional items.
• Code audits of security-relevant areas; for example, the Classroom's access and billing code was audited on 28 September 2026 and the findings fixed.
• A Content Security Policy runs in report-only mode and records violations before it is enforced.

Measures for user identification and authorisation

• Sign-in through Supabase Auth with e-mail and password (passwords stored only as salted hashes) or with Sign in with Google.
• A CAPTCHA (Cloudflare Turnstile), verified by Supabase Auth itself, protects sign-up, sign-in, password reset and re-sending of confirmation e-mails.
• Roles per School Account: Student, Teacher, Owner. Every Classroom request is re-authorised on the server: the App checks, for the specific School named in the request, that the signed-in person is an active Teacher or Owner of an active School (requireModerator), or an Owner (requireOwner). The cookie that selects which School the portal shows is never trusted as authority.
• Only the Paying Owner can change Seats or the Licence Tier. Teachers never see billing. Teachers of a suspended School lose access entirely; its Owners see only Plan & Billing.
• Students can read only their own membership and assignment records. No database policy gives Teachers direct access to other people's records: every Teacher read and every write runs in server code, after the check above, with a server-only service key. No client may write to Classroom tables directly. The Minute Pack allocation table has no client policy at all (server-only).
• The function that resolves an invited e-mail address to an account can be called only by the server.
• ntagks's own administrators are identified by a flag on their account, checked on the server for every admin page and admin request.

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Measures for the protection of data during transmission

• TLS for all traffic between browsers, the App and the providers.
• E-mails are sent through Resend from the authenticated domain certifyboost.com (SPF, DKIM and DMARC records).
• Payment webhooks from Stripe are accepted only with a valid signature.

Measures for the protection of data during storage

• Classroom Data is stored in the EU (Dublin, Ireland).
• Students' speaking recordings (Learner Account data, not Classroom Data) are kept in a private storage bucket and are reachable only through signed links; playback links expire after 60 seconds. The Classroom shows essays, recordings, transcripts or AI feedback text to Teachers only for a score a Student has asked them to review (Annex B, clause 2.6), and only to the Teachers of that Student's class (the Owners, for a Student in no class).
• The service key that bypasses row-level security exists only in the server environment and is never sent to browsers.

Measures for ensuring physical security of locations at which personal data are processed

• ntagks operates no servers. Data is processed in the data centres of the sub-processors in Annex IV, which are covered by their own certifications and reports.
• The proprietor's work computer uses full-disk encryption and an automatic screen lock.

Measures for ensuring events logging

• The hosting providers keep request, authentication and database logs for a few days.
• The App records who sent each invitation and who created each class and assignment, with timestamps.
• Processed payment events are recorded, so that each is applied only once.

Measures for ensuring system configuration, including default configuration

• Default deny: row-level security is enabled on every table, and tables without a policy are reachable only by the server.
• Execution rights on sensitive database functions are revoked from public roles.
• Security headers on both web applications: HSTS, X-Frame-Options DENY, X-Content-Type-Options nosniff, Referrer-Policy and Permissions-Policy.
• Text controlled by a School (for example its name) is escaped before it is inserted into e-mails.

Measures for internal IT and IT security governance and management

• One responsible person (the proprietor) for security and data protection.
• Written runbooks for database migrations, e-mail and production launch.
• Secrets are kept in the hosting providers' environment settings and rotated when exposure is suspected.
• AI-assistant tooling has read-only access to production.

Measures for certification/assurance of processes and products

• ntagks holds no certification. It relies on the certifications and audit reports of its sub-processors.

Measures for ensuring data minimisation

• Teachers and Owners see only the data listed in Annex B of the School Agreement. They do not see Students' essays, recordings, transcripts, AI feedback text, section-level scores, date of birth or country, except for the one piece of work behind a score a Student asks them to review.
• The e-mail address shown for a Student is the one the School itself entered.
• Students can hide themselves from rankings in their settings.
• Each Student is in at most one class.

Measures for ensuring data quality

• E-mail addresses are validated and normalised when entered.
• Classes and assignments are always validated against the School they belong to.

Measures for ensuring limited data retention

• Classroom Data is deleted no later than 30 days after the School Agreement ends (Part 2, B8).
• A revoked invitation that was never accepted is deleted at once.
• When a person deletes their Learner Account, it is disabled at once and erased after 30 days, including their Classroom memberships and invitations.
• Backups roll over after 7 days. Resend keeps delivery logs for 30 days.

Measures for ensuring accountability

• This DPA, records of the School's acceptance (the version accepted, when and by whom, with the exact wording; School Agreement clause 3.6), records of processing (to be prepared) and a data protection impact assessment for the platform (to be prepared).

Measures for allowing data portability and ensuring erasure

• Copies of Classroom Data in CSV or JSON on request (Part 2, B5.4 and B8.1).
• Erasure as described under "limited data retention".

Specific measures to assist the controller (Clause 8(d) and Clause 9)

• Requests from data subjects: forwarding within 3 Business Days; copies of a named person's Classroom Data within 10 Business Days (Part 2, B5).
• Breaches: an incident procedure (detect, contain, assess, notify the School within 48 hours, document, review), with the notification content in Part 2, B4.
• DPIA support: Annex II, this Annex, Annex IV and the relevant parts of ntagks's own risk assessment (Part 2, B6).

Annex IV: List of sub-processors

The controller has authorised the use of the sub-processors in Part A. Part B lists the other providers that are part of the Service but do not process Classroom Data; it is given for transparency and is not part of the agreed list. The information follows section 4 of ntagks's Privacy Policy.

Part A: Sub-processors for Classroom Data

Part B: Other providers (not sub-processors for Classroom Data)