Data processing agreement

1. Parties and subject matter

This agreement is concluded between the client who uses ACM for their brand (the “Controller”) and Archetypal Coherence Matrix (ACM Framework), a service operated by MEDIA KSW Limited Liability Company, IDNO 1016600037745, with its registered office at MD-6812, Chisinau municipality, Bacioi village, 6 Europa Boulevard, Republic of Moldova (the “Processor”). It supplements the Terms and applies to the personal data that the Controller uploads or collects through the Service.

2. The Controller's instructions

ACM processes the data only on the Controller's documented instructions, that is, through the settings and actions made in the platform, and only in order to provide the Service.

3. ACM's obligations

• Keeps the data confidential and requires the same of its people.
• Helps the Controller respond to requests from data subjects.
• On termination of the contract, deletes or returns the data, at the Controller's choice.

4. Sub-processors

ACM may use the sub-processors in the Processors list. Before adding a new one, it notifies the Controller, who may object on reasonable grounds.

5. Security of processing

ACM applies technical and organisational measures appropriate to the risk: encryption of data in transit, role-based access, logging of administrative access and backups.

6. Verification

On request, ACM makes available to the Controller the information necessary to verify compliance with this agreement.

7. Security breaches

ACM notifies the Controller without undue delay after becoming aware of a personal data breach and gives the Controller the information it needs to report it.

8. Transfers to third countries

Transfers outside the European Economic Area are made only with appropriate safeguards, for example standard contractual clauses.

9. Annex I · Description of the processing

Data subjects: the brand's users, survey respondents, clients in the uploaded lists.

Data: name, email, survey responses, demographic data chosen by the respondent.

Purpose: measuring brand coherence with the ACM method.

10. Annex II · Technical and organisational measures

• Encryption of connections (HTTPS).
• Role-based access and audit log.
• Regular backups.
• Deletion of data on request and on termination.

11. Annex III · List of sub-processors

The current list is published at Processors.