Data Processing Agreement (summary) — MandarinMiles

Data Processing Agreement (summary)

Last updated: 11 November 2026

Scope: This page summarises the terms that apply where David Yuan (“Processor”) processes personal data on behalf of a school, district or business customer (“Controller”) using MandarinMiles, as required by Article 28 GDPR / UK GDPR. A countersigned agreement and the current sub-processor register are available from [email protected]. For individual consumers we are the controller, not a processor — see the Privacy Policy.

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.

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