Data Processing Agreement

Version 1.0 · Effective: June 5, 2026 · GDPR Article 28 compliant

This DPA forms part of the ZonForge Terms of Service. By using ZonForge Sentinel, customers who are subject to GDPR or CCPA data processing requirements agree to this DPA. For a signed copy, contact legal@zonforge.com.

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1. Definitions

"Controller" means the ZonForge customer determining the purposes and means of processing personal data.
"Processor" means ZonForge Inc., processing personal data on behalf of the Controller.
"Personal Data" means any information relating to an identified or identifiable natural person.
"Processing" has the meaning given in Article 4(2) GDPR.
"Sub-processor" means a third party engaged by ZonForge to process Personal Data.

2. Scope and Nature of Processing

Subject matterProcessing of Personal Data to provide security monitoring, threat detection, and risk scoring services
DurationFor the duration of the subscription agreement plus data retention period
Nature and purposeIngestion, normalization, correlation, analysis, and reporting of security event data
Type of Personal DataIdentity attributes (user emails, IDs), IP addresses, device identifiers, system access logs, authentication events
Categories of data subjectsController's employees, contractors, system accounts, and users in monitored environments

3. Processor Obligations

ZonForge (as Processor) will:

4. Security Measures

ZonForge implements the following safeguards for all Personal Data:

5. Sub-processors

The Controller authorizes ZonForge to engage the following sub-processors:

Sub-processorLocationPurpose
Amazon Web ServicesUS-East-1 (Virginia)Cloud infrastructure, storage, compute
Stripe Inc.United StatesPayment processing
Resend Inc.United StatesTransactional email
Sentry (Functional Software)United StatesApplication error tracking (anonymized)
Anthropic PBCUnited StatesAI analysis (event data anonymized before transmission)

ZonForge will provide 30 days' notice of any new sub-processors. The Controller may object within this period.

6. International Data Transfers

Personal Data from the EEA/UK is transferred to the United States under Standard Contractual Clauses (SCCs) as adopted by the European Commission in Decision 2021/914 (Module 2: Controller to Processor). The SCCs are incorporated by reference and available upon request.

7. Data Subject Rights

ZonForge will assist the Controller in fulfilling data subject rights requests (access, rectification, erasure, portability) within technically feasible means. ZonForge will not independently respond to data subjects — Controller remains the point of contact.

8. Data Breach Notification

ZonForge will notify the Controller without undue delay and within 72 hours of becoming aware of a Personal Data breach. Notification will include: the nature of the breach, categories and approximate number of data subjects and records affected, likely consequences, and measures taken or proposed.

9. Data Deletion

Upon termination of the subscription, ZonForge will delete all Customer Personal Data within 30 days unless required by law to retain it. Controller may request a written confirmation of deletion.

10. Audit Rights

The Controller may audit ZonForge's compliance with this DPA at most once per year with 30 days' prior written notice, at Controller's expense. ZonForge may satisfy audit obligations by providing current SOC 2 or ISO 27001 audit reports.

11. Governing Law

This DPA is governed by the laws of the jurisdiction of the Controller's principal place of business, except where EU GDPR applies, in which case EU law governs matters relating to GDPR compliance.

Contact

Data Protection Officer: dpo@zonforge.com
Legal: legal@zonforge.com