Legal
Data Processing Agreement
Effective October 19, 2026
This Data Processing Agreement (“DPA”) forms part of the Terms of Service between Franklin Lupichuk, a sole proprietor carrying on business as Rendro (“Rendro”) and the Customer. It applies when Rendro processes personal information on the Customer’s behalf. If this DPA and the Terms conflict on data protection, this DPA wins.
1. Roles and definitions
“Customer Personal Data” means personal information in the content the Customer uploads to Rendro (documents, questionnaires, answers and comments) that Rendro processes on the Customer’s behalf. “Data Protection Laws” means the privacy laws that apply to that processing, which may include PIPEDA and Canadian provincial laws, the EU and UK General Data Protection Regulation, and US state privacy laws.
The Customer is the controller (or the organization responsible for the information). Rendro is the processor (or service provider).
2. Processing only on instructions
Rendro processes Customer Personal Data only to provide the service, following the Customer’s documented instructions: the Terms, this DPA and the Customer’s use of Rendro. Rendro will tell the Customer if it believes an instruction breaks Data Protection Laws.
Rendro does not sell or share Customer Personal Data, does not use it for its own purposes, and does not use it to train AI models.
3. Confidentiality
Everyone at Rendro who can access Customer Personal Data is bound by confidentiality.
4. Security
Rendro maintains the technical and organizational measures in Annex A and may improve them over time without reducing the overall level of protection.
5. Subprocessors
The Customer authorizes Rendro to use the subprocessors listed on the subprocessors page. Rendro will announce a new subprocessor on that page and by email to workspace owners at least 30 days before it starts processing Customer Personal Data. The Customer may object on reasonable data protection grounds; if we can’t resolve the objection, the Customer may end its subscription and receive a refund of prepaid fees for the unused period.
Rendro requires its subprocessors to protect the data under written terms and remains responsible for them.
6. Personal data breaches
Rendro will notify the Customer without undue delay, and within 72 hours, after becoming aware of a breach affecting Customer Personal Data. The notice will include what Rendro knows at the time and will be updated as more is learned. Rendro will help the Customer meet its own notification duties.
7. Help with requests and assessments
Most requests from individuals (to see, correct or delete their information) can be handled by the Customer directly in Rendro. Rendro will otherwise give reasonable help with such requests, and with data protection impact assessments and consultations with regulators, taking into account the information available to it.
8. Deletion and return
The Customer can export its questionnaires and Answer Library at any time. After the Customer deletes its workspace, or on the Customer’s request when its subscription ends, Rendro deletes Customer Personal Data within 30 days. Copies in backups are deleted as the backups expire, within a further 30 days, unless the law requires Rendro to keep them. Rendro will confirm deletion in writing on request.
9. Audits
On request, Rendro will provide the information reasonably needed to show compliance with this DPA, such as its security overview and completed security questionnaires. On-site audits are available only where a regulator requires one or after a breach affecting the Customer, with reasonable notice, at the Customer’s cost, and no more than once a year.
10. International transfers
Customer Personal Data is stored in the United States and processed there by Rendro’s subprocessors. Rendro protects it with contractual commitments comparable to those required by Canadian law. If the Customer needs the EU Standard Contractual Clauses or the UK Addendum for personal data from the European Union or the United Kingdom, Rendro will sign them on request.
11. Liability and term
Each party’s liability under this DPA is subject to the limitation of liability in the Terms. This DPA applies for as long as Rendro processes Customer Personal Data.
Annex A: Security measures
- Encryption of data in transit (HTTPS with HSTS) and at rest (by our database and storage provider).
- Strict separation between workspaces enforced in the database (row-level security), covered by automated tests.
- Role-based access within each workspace (owner, admin, editor, reviewer).
- Private file storage; downloads use links that expire after 60 seconds.
- Access to production systems limited to Rendro’s founder.
- An audit log of important actions in each workspace.
- Rate limits on sign-in, uploads and AI features, and daily limits on AI use.
- A strict Content Security Policy and other browser security headers.
- Uploaded content treated as untrusted data: the AI is instructed to treat it as data and to ignore any instructions inside it, and these defences are covered by automated tests.
- Automated tests of the application, including workspace separation, and dependency monitoring.
- An incident response process with customer notification within 72 hours.
Annex B: Details of processing
- Subject matter: providing the Rendro questionnaire-answering service.
- Duration: the subscription, plus the deletion period in section 8.
- Nature and purpose: storing, indexing (search vectors), searching and drafting answers from Customer content; account management; support.
- Categories of people: the Customer’s users, and people named in Customer content (such as employees, contractors and contacts).
- Categories of personal data: names, business contact details, job titles, and any other personal information the Customer chooses to include in uploaded content.
- Sensitive data: not intended; the Terms ask customers not to upload it.
- Frequency: continuous during the subscription.
Questions about this DPA: privacy@rendro.net.