Data Processing Agreement

Last updated: April 11, 2026

1. Definitions

"Data Controller" means the Customer (you), who determines the purposes and means of processing personal data using the Service.

"Data Processor" means Kiuei, which processes personal data on behalf of the Data Controller in connection with providing the Service.

"Personal Data" means any information relating to an identified or identifiable natural person, as defined under the General Data Protection Regulation (GDPR).

2. Purpose and Scope of Processing

The Data Processor shall process Personal Data only for the purposes of providing the Kiuei test management platform, including:

Processing is limited to the data categories necessary to deliver the Service as described in our Terms of Service.

3. Data Subject Rights

The Data Processor shall assist the Data Controller in fulfilling obligations to respond to Data Subject requests, including:

The Data Processor will respond to such requests within 30 days and notify the Data Controller without undue delay.

4. Security Measures

The Data Processor implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

5. Sub-Processors

The Data Processor may engage sub-processors to assist in providing the Service. Current sub-processors include:

The Data Processor shall notify the Data Controller of any intended changes to sub-processors, providing the Data Controller with an opportunity to object. Sub-processors are bound by data processing obligations no less protective than those in this agreement.

6. Data Breach Notification

In the event of a personal data breach, the Data Processor shall:

7. Data Deletion Upon Termination

Upon termination or expiry of the Service agreement:

8. GDPR Compliance

Both parties agree to comply with their respective obligations under the General Data Protection Regulation (EU) 2016/679 and any applicable national implementing legislation. The Data Processor shall:

9. International Data Transfers

Where Personal Data is transferred outside the European Economic Area (EEA), the Data Processor shall ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or other valid transfer mechanisms under GDPR.

10. Contact Information

For any questions or requests related to this Data Processing Agreement, please contact us at:

dpa@kiuei.com