Data Processing Agreement (DPA)

Connie ApS – Company Registration No. DK-42768294

Last updated on November 4th, 2026

Get a signed copy

Get a signed copy of our Data Processing Agreement

Below is our Data Processing Agreement (DPA), describing how we store, protect, process, access, and use the data we process on your behalf. Our DPA is based on the EU Commission’s Standard Contractual Clauses for Data Processing Agreements, dated June 4th, 2021.

Preamble

Section I

Clause 1

Purpose and scope

(a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

(b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29 (3) and (4) Regulation (EU) 2018/1725.

(d) Annexes I to IV are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2

Invariability of the Clauses

(a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3

Interpretation

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4

Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5

Docking clause

(a) Any entity that is not a Party to these Clauses may, with the agreement of all the Parties, accede to these Clauses at any time as a controller or a processor by completing the Annexes and signing Annex I.

(b) Once the Annexes in (a) are completed and signed, the acceding entity shall be treated as a Party to these Clauses and have the rights and obligations of a controller or a processor, in accordance with its designation in Annex I.

(c) The acceding entity shall have no rights or obligations resulting from these Clauses from the period prior to becoming a Party.

Section II

Obligations of The Parties

Clause 6

Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7

Obligations of the Parties

7.1. Instructions

(a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing

(a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

7.6. Documentation and compliance

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7. Use of sub-processors

(a) The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least ninety (90) days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

(e) The processor shall agree a third party beneficiary clause with the sub-processor whereby – in the event the processor has factually disappeared, ceased to exist in law or has become insolvent – the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8. International transfers

(a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8

Assistance to the controller

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions.

(c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

(1) the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;

(2) the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;

(3) the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;

(4) the obligations in Article 32 Regulation (EU) 2016/679.

(d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9

Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 Regulation (EU) 2016/679 or under Articles 34 and 35 Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

(b) in obtaining the following information which, pursuant to Article 33(3) Regulation (EU) 2016/679, shall be stated in the controller’s notification, and must at least include:

(1) the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;

(2) the likely consequences of the personal data breach;

(3) the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c) in complying, pursuant to Article 34 Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

Section III

Final Provisions

Clause 10

Non-compliance with the Clauses and termination

(a) Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

(1) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;

(2) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;

(3) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

(d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

Annex I

List of Parties

Controller(s):

Identity and contact details of the controller(s), and, where applicable, of the controller’s data protection officer appears from the main agreement between the controller and processor, which these Clauses are an integrated part of.

Processor(s):

Name: Connie ApS

Address: Brandts Passage 15, 2. 20, 5000 Odense C

Contact person’s name, position and contact details:

Name: Daniel Gjøde
Position: Founder & CEO

Contact details:
Email: daniel@getconnie.com / phone number +45 22 15 43 40

Annex II

Description of The Processing

Categories of data subjects whose personal data is processed

Employees of the controller (Customer) and people, including children and minors, or entities (Signers) signing documents issued by the controller.

Categories of personal data processed

For Controller

Full name
Email address
Company name and details
Log data: IP address, timestamp, browser type and a cryptographic hash for the document
Phone number (optional)
Company department (optional)
Photo of employee of controller (optional)

For Signers

Full name
Age (to determine whether parental consent is required)
Email address
Log data: IP address, timestamp, browser type and a cryptographic hash for the document
Photo/Selfie (optional)
Phone number (optional)
Address (optional)
Social Security Number (CPR) (optional)
Bank information (optional)
Nationality (optional)
Other details requested at the controller’s discretion (optional)

Sensitive data processed (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.

Customers may – with the right permissions – create their own form fields for data subjects to fill in. As such, Customers can decide knowingly or unknowingly to collect sensitive data.
Information, including type of phone, email, city, ZIP, country, company name, Company Registration No. and title may also be collected via SmartTags if the Controller has enabled this.
Where reasonable, the processor will take precautions to inform the Customer to mitigate the risk of collecting sensitive data.
It is the sole responsibility of the controller to ensure that the controller either does not collect sensitive data or applies a valid legal basis for the processing.
As additional safeguards to mitigate the risk of sensitive data accidentally being stored on the platform, data is encrypted and segregated per customer, and the processor’s personnel do not access the controller’s data in the ordinary course of operating the platform. Where access is necessary – for support at the controller’s request, for error resolution or for security purposes, or where required by law – it is limited to authorised personnel bound by confidentiality, granted on a need-to-know basis under the processor’s internal access procedures, and logged.

Nature of the processing

Storing, retrieving, using, disclosing and erasing of personal data on behalf of the controller.

Purpose(s) for which the personal data is processed on behalf of the controller:

The purpose of the processing on behalf of the controller is to provide the processor’s e-Signing platform Connie to the controller, enabling the controller to draft, issue and manage contracts, consent forms and other documents and agreements to signers.

AI-assisted features. The processor offers optional AI-assisted features, which are disabled by default. Processing carried out through these features, including the engagement of AI-specific sub-processors, is governed by the AI-Assisted Processing Addendum, which applies only where the controller has expressly enabled the features and accepted the Addendum. The Addendum is available in the processor’s Trust Center. Where the controller has not accepted the Addendum, no personal data is processed through AI-assisted features and no AI-specific sub-processors are engaged.

Duration of the processing

The processing has no set duration and may continue until the controller ceases the use and processing of personal data on the processor’s platform or until the effective termination of these Clauses.

Deletion and return of data (Clause 10(d)). When the main agreement ends – by termination, non-payment or expiry of a trial period – the controller’s account enters a retrieval period of thirty (30) calendar days, during which the controller can export its documents free of charge using the export functionality in Connie. This export functionality constitutes the standard means by which personal data is returned to the controller. Upon expiry of the retrieval period, the processor permanently deletes the account and all personal data processed on the controller’s behalf, and confirms the deletion to the controller by email; this confirmation constitutes the certification of deletion under Clause 10(d). Copies in backups are purged within thirty (30) days thereafter. The processor may retain data where and for as long as storage is required by Union or Member State law (such as invoicing records under the Danish Bookkeeping Act). Copies of signed documents that signers have chosen to keep in their own Signer Document Archive are processed by the processor as an independent controller under its General Privacy Policy and are not affected by deletion of the controller’s account. Where an enterprise agreement specifies different export, retention or deletion terms, those terms prevail.

For processing by (sub-) processors, also specify subject matter, nature and duration of the processing:

Please refer to this page on the processor’s Trust Center for a list of current sub-processors.

Annex III

Technical and organisational measures to ensure the security of the data.

Please refer to this page on the processor’s Trust Center for details on the processor’s technical, organizational and product security measures and controls to ensure security of the controller’s personal data.

The processor is ISO 27001:2022 certified. A copy of the certification is available on the processor’s Trust Center and may also be sent to the controller directly upon request. The processor aims to renew the ISO 27001:2022 certification once (1) a year.

The processor’s control environment is also maintained in alignment with the SOC 2 Trust Services Criteria for security, availability and confidentiality. The processor does not currently commission a separate SOC 2 attestation, as the ISO/IEC 27001:2022 certification already provides annual, independent third-party assurance covering the same control domains. A SOC 2 Type II report may be commissioned where required under an enterprise agreement.

Last updated on November 4th, 2026

Changelog

November 4th 2026.
Restored Clause 7.6 (c) and the point lettering in Clause 7.7 to the European Commission’s standard text; supplementary information now appears only in the Annexes.
Updated Annex III on assurance: the processor’s ISO 27001:2022 certification is the annual, independent third-party assurance for this DPA; a SOC 2 Type II report can be commissioned under an enterprise agreement.
Updated Annex II to describe the processor’s access model more precisely: personnel do not access controller data in the ordinary course of operations, and any necessary access is permission-based, need-to-know, procedure-governed and logged.
Updated Annex II on the categories of data subjects and personal data processed: signers may include children and minors; added age, Social Security Number (CPR), bank information and nationality as optional signer data; and noted that structured data may be collected via SmartTags where enabled by the controller.
Added to Annex II a description of the deletion and return process under Clause 10 (d): a 30-day retrieval period with free self-service export, permanent deletion with email confirmation serving as certification, backup purge within 30 days, and statutory retention carve-outs – aligned with Section 10 of the Terms & Conditions (Version 6).
Added a reference in Annex II to the optional AI-Assisted Processing Addendum, which applies only upon the controller’s explicit acceptance.
Minor grammatical corrections.

June 4th 2025.
Updated sec. 7.6 (c) regarding the processor’s obtained ISO 27001:2022 certification and plans for obtaining SOC 2, and the controller’s right to request amendments to the DPA and to request additional technical and organizational measures based on the controller’s audit of the processor.
Amended the timeframe in sec. 7.7 (a) for when the processor shall specifically inform in writing the controller of any intended changes of the list of sub-processors through the addition or replacement of sub-processors to at least ninety (90) days in advance.
Updated Annex II on list of sub-processors and Annex III on technical and organizational measures to reference the processor’s Trust Center with updated information.
Added reference to processor’s ISO 27001:2022 certification and SOC 2 audit.
Minor grammatical adjustments and clarifications.

March 12th 2024.
Company name updated to Connie ApS.
Contact details for processor updated from daniel@connie.page to daniel@getconnie.com