Data Processing Agreement (summary)
1. Subject matter and scope
Processing of names/identifiers, seat levels, saved words, reading progress and account activity supplied by the Controller, for the purpose of delivering graded readers, progress tracking and related support, for the duration of the service agreement.
2. Roles and instructions
The Controller determines the purposes and means. The Processor acts only on documented instructions (this agreement plus the Controller’s configuration and written requests), and will inform the Controller if an instruction appears to infringe applicable data-protection law. The Processor will not use Controller data for its own purposes, advertising or AI-model training.
3. Confidentiality and security
Staff with access are bound by confidentiality. Technical and organisational measures include TLS in transit, role-based access controls, optional two-factor authentication, signed webhooks, rate-limiting, isolated page caching for logged-in and sensitive pages, protected audio delivery, and security-event logging. Sub-processors are bound by equivalent obligations.
4. Sub-processors
Core categories: hosting and database; transactional email (Zoho Mail); content delivery and bot protection (Cloudflare); Merchant of Record and payment processing (Creem, with PayPal for one-time purchases); speech synthesis for reader narration. The Controller is notified of material changes in advance and may object on reasonable data-protection grounds.
5. Assistance and rights requests
We assist the Controller with data-subject requests, breach assessment, data-protection impact assessments and prior consultation, taking into account the nature of processing and the information available to us. Requests from individuals are forwarded to the Controller without undue delay where they relate to Controller data.
6. International transfers
Transfers outside the EEA/UK rely on an adequacy decision (including the EU-US Data Privacy Framework / UK Extension where applicable) or Standard Contractual Clauses together with a transfer-impact assessment and supplementary technical measures. Details are available on request.
7. Personal-data breaches
We notify the Controller without undue delay after becoming aware of a personal-data breach affecting Controller data, and provide the information reasonably needed for the Controller’s own regulatory notification.
8. Deletion and audit
On termination, Controller data is deleted or returned at the Controller’s choice within 30 days, except where law requires limited retention of billing records. We make available information necessary to demonstrate compliance and allow audits subject to reasonable notice and confidentiality safeguards.
9. Contact
Countersigned copies, the sub-processor register and notices: [email protected] · Contact & Imprint.
MandarinMiles is operated by David Chen, an individual based in mainland China.