Data Processing Addendum
DATA PROCESSING ADDENDUM (v2.2)
Last Updated: 2025-11-02
This Data Processing Addendum is incorporated into the IPWho Terms of Service and is binding on IPWho and the Customer without requiring a signature.
1. ROLES
- Customer = Controller
- IPWho = Processor
2. PURPOSE
Processing IP addresses, logs, and account metadata to provide the Service.
3. CUSTOMER INSTRUCTIONS
Instructions must be lawful and in writing. We may reject instructions violating law or degrading the Service.
4. SECURITY
We employ the following security measures:
- Encryption
- Access control
- Monitoring
- Retention limits
5. SUBPROCESSORS
Categories listed in the Subprocessors Notice. Full list available upon request.
6. INTERNATIONAL TRANSFERS
Standard Contractual Clauses are incorporated.
7. DATA REQUESTS
We assist with GDPR/CCPA data subject requests submitted by Customer.
8. INCIDENT RESPONSE
We will notify the Customer without undue delay of any data incident.
9. CONTACT
ANNEX II — TECHNICAL & ORGANISATIONAL MEASURES
- Encryption
- IAM (Identity and Access Management)
- Monitoring
- Backups
- Log rotation