Data processing agreement
Last updated 2026-10-23.
This agreement is part of the terms of service between Angelo Lamonaca (sole proprietorship), trading as Neuramare (“we”, the processor) and the customer (“you”, the controller), wherever we process personal data on your behalf. It meets Art. 28 of the EU General Data Protection Regulation (GDPR) and Art. 9 of the Swiss Federal Act on Data Protection (FADP). Accepting the terms accepts it; no signature is needed, and we sign a copy on request.
1. What we process
- Subject and purpose: providing Kennmarq.com as the terms describe: marking, checking and safety-checking the files you send, signing manifests, keeping the records the service needs.
- Duration: as long as the terms run, and then until the data is deleted as section 7 says.
- Personal data: whatever the files you send hold (pictures may show people), what you declare in marks (you shouldn't put personal data there), and the identifiers in our records of each mark.
- Data subjects: people who appear in or made the files you send, and your users whose actions cause calls.
- Special categories: the safety check estimates whether a picture shows nudity, an apparent minor or a realistic face, to block or flag it. It doesn't identify anyone and stores nothing of the picture: no biometric data is kept, and no age is returned.
2. Your instructions
We process the data only on your documented instructions: these terms, the documentation, and how you call the API. If we believe an instruction breaks data protection law, we tell you. We process nothing for our own purposes, except where the law requires it, and then we tell you unless the law forbids it.
3. Confidentiality and security
Everyone who can access the data is bound to confidentiality. We keep the technical and organisational measures in the annex, and may improve them, never below the level described.
4. Sub-processors
You authorise the sub-processors on the sub-processors page. We bind each to terms that protect the data as this agreement does, and remain responsible for them. We announce a new sub-processor at least 30 days before it starts, on that page and by email to organisation owners; you may object on reasonable data protection grounds, and if we can't resolve the objection, end the agreement before the change, with a refund of any fees paid for the time after it.
5. Transfers
Customer data stays in Switzerland and the EU (section 1 of the annex). Where a sub-processor processes personal data in a country without adequate protection, the transfer is covered by the EU Standard Contractual Clauses with the Swiss addendum, or by a certification under the EU–US or Swiss–US Data Privacy Framework.
6. Help with your duties
- We help you answer data subjects' requests, with the tools in the dashboard and the API, and on request.
- We help with data protection impact assessments and prior consultations, as far as our part of the processing goes.
- We notify you of a personal data breach that affects your data without undue delay, within 48 hours of becoming aware of it, with what we know then and the rest as we learn it.
7. At the end
When the terms end, we delete your account data within 30 days, and from backups within 7 days after that; files were never kept. What stays: the transparency log's entries, which hold hashes and no personal data, durable credentials of files you marked (so marks stay verifiable), and what the law makes us keep, such as invoices.
8. Proof and audits
We make available what shows that we meet this agreement: the trust center, our answers to security questionnaires, and the transparency log. If that isn't enough, you may audit us, or have an independent auditor bound to confidentiality do so, once a year, with 30 days' notice, at your cost, without access to other customers' data. Our sub-processors are audited under their own certifications (for AWS: ISO 27001, SOC 2).
9. Liability and order
The terms' exclusion of liability (their section 10) applies to this agreement too, as far as data protection law allows. Otherwise, where this agreement and the terms differ on personal data, this agreement prevails.
Annex: technical and organisational measures
| Where | Customer data is kept in AWS's Zurich region; database backups are copied to Frankfurt. Requests pass through the API in Frankfurt, in memory. |
|---|---|
| Encryption | TLS 1.2 or later in transit, to the public and between our services; storage and backups encrypted at rest (AES-256); secrets in AWS Systems Manager, encrypted with AWS KMS. |
| Keys | Signing keys are created in AWS KMS and never leave it; each call may make a fixed number of signatures, of bounded size. |
| Access | Least-privilege roles for each function; the marker and the time-stamp server have no public address; the database admits the app only with short-lived IAM tokens over TLS; administrative access needs multi-factor authentication. |
| Minimisation | Files are processed in memory and not stored; uploads are deleted once used, within an hour at the latest; logs hold no file contents and no IP addresses. |
| Integrity | Every signature and time-stamp goes into an append-only public transparency log; each organisation's audit log is hash-chained and anchored in it. |
| Availability | Managed, redundant AWS services; daily database backups kept 7 days, copied to a second region; a status page checked from a third region. |
| Testing | Automated and end-to-end tests before every release, including fail-closed checks: a file that isn't marked as asked is never returned. |
Contact for this agreement: privacy@kennmarq.com.