Data Processing Addendum
This addendum (“DPA”) forms part of the Terms of Service between [LEGAL ENTITY NAME] (“WireEngine”, the processor) and the business customer that accepts it (“Customer”, the controller) when Customer uses WireEngine to process personal data about its own clients — for example vessel owners whose projects Customer designs or hands over.
1. Scope and roles
- Subject matter: hosting and processing project data Customer enters about its clients’ vessels to provide the service.
- Duration: the term of Customer’s subscription plus the deletion period in section 8.
- Data subjects: Customer’s clients and their contacts; Customer’s staff using seats.
- Personal data: names and contact details Customer enters, vessel identity and location details, equipment photos (including any embedded metadata), uploaded manuals, maintenance records, and account emails of Customer’s users.
- Special-category data: none intended; Customer will not enter it.
- For Customer’s own account and billing data, WireEngine is a controller under its Privacy Policy.
2. Instructions
WireEngine processes personal data only on Customer’s documented instructions, which are these terms and Customer’s use of the service’s features (including choosing to use AI features), unless the law requires otherwise — in which case WireEngine will tell Customer first where it lawfully can.
3. Confidentiality
Everyone at WireEngine authorised to access personal data is bound by confidentiality. Access to production data is limited to those who operate the service.
4. Security
WireEngine maintains the measures in Annex 2, including encryption in transit, salted password hashing, per-project access checks on every request, rate-limited sign-in, security headers and upload content checks.
5. Subprocessors
Customer authorises the subprocessors in Annex 1. WireEngine will give at least 30 days’ notice by email of a new or replacement subprocessor; Customer may object on reasonable data-protection grounds, and if the objection cannot be resolved, terminate the affected service with a pro-rata refund of prepaid fees for it. WireEngine imposes data-protection obligations on each subprocessor no less protective than this DPA and remains responsible for them.
6. Assistance
WireEngine will help Customer respond to data-subject requests (the app provides export and deletion), and with security, breach notification, impact assessments and prior consultation, taking into account the nature of the processing.
7. Personal data breaches
WireEngine will notify Customer without undue delay, and in any case within [48 hours], after becoming aware of a personal data breach affecting Customer data, with the information Customer needs to meet its own obligations.
8. Deletion and return
Customer can export and delete its data at any time in the app. On termination, WireEngine deletes Customer data within [30 days], and backups roll off within a further [30 days], unless the law requires retention. See the Retention and Deletion Policy.
9. Audits
WireEngine will make available the information reasonably necessary to demonstrate compliance with this DPA, and allow audits by Customer or its auditor on 30 days’ notice, no more than once a year, at Customer’s cost, subject to confidentiality.
10. International transfers
Where personal data is transferred outside the UK or EEA, the parties rely on [Standard Contractual Clauses (module 2/3) and the UK Addendum — to be confirmed by counsel].
Annex 1 — Subprocessors
| Subprocessor | Purpose | Data | Location |
|---|---|---|---|
| Railway | Application hosting, database and file storage | All Customer data | [region] |
| Vercel | Website and web-app hosting | IP address and page requests | [region] |
| Anthropic | AI model for the design assistant, used only when a user invokes an AI feature | Design descriptions, chat messages with a project summary and manual passages, troubleshooting symptoms with project facts, photos submitted for identification | United States [confirm] |
| Stripe | Payments and subscriptions | Customer billing contact and payment details | United States / [entity] |
| Resend | Account and invitation email | Email addresses, message content | United States [confirm] |
| Sentry (planned) | Error monitoring | Error details, IP address, browser | [region] |
Annex 2 — Security measures
- HTTPS everywhere with HSTS; Content-Security-Policy and other security headers.
- Passwords stored as salted scrypt hashes; signed session tokens revoked on password change and sign-out; sign-in and registration attempts throttled.
- One access check on every project route; a project not owned by the requesting account is reported as absent.
- Uploaded files checked against their declared type; body-size limits.
- Photos served through short-lived signed links.
- No third-party scripts or fonts on the website or app.
- AI features cannot write safety values; free text from the model is scanned for them.
- [Backups, monitoring and penetration-test status to be confirmed before publication.]