Between you as the controller and RevEx Solutions GmbH as the processor, Article 28 GDPR.
The legally binding version of this document is the German version. This English translation is provided for convenience only. The Clauses themselves are reproduced from the official English language version of the Annex to Commission Implementing Decision (EU) 2021/915.
Version 2026-08-v1 · Sub-processor list as of 17 August 2026
This agreement adopts the European Commission's Standard Contractual Clauses (Implementing Decision (EU) 2021/915 of 4 June 2021, OJ L 199, 7.6.2021, p. 18–30) without modification. Only those places the template itself provides for completion have been filled in: the options and Annexes I to IV.
Official text: eur-lex.europa.eu → CELEX:32021D0915
When you use ImperIQ, we process personal data on your behalf — data of your staff, your business partners and your contacts. Article 28 GDPR requires a contract for this. This is that contract.
You remain the controller. We process data solely on your instructions.
Not to be confused with the data processing agreements you yourself manage under Settings → Compliance & Legal for your own customers and service providers.
| Place | Choice | Reason | |---|---|---| | Clause 1(a) | Option 1 — Article 28(3) and (4) GDPR | We are a company, not a Union institution. The alternative (Regulation (EU) 2018/1725) applies only to EU bodies | | Clause 5 (optional) | included | Allows affiliated companies on your side to accede later | | Clause 7.7(a) | Option 2 — general written authorisation, period 30 days | With eleven sub-processors, specific authorisation would turn every provider change into a contract amendment with every customer. We keep transparency at the level of Option 1 voluntarily: Annex IV is maintained even though Option 2 does not require it | | Clauses 8 and 9 | Option 1 (GDPR) in each case | Same reason as Clause 1 |
(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, and repealing Directive 95/46/EC (General Data Protection Regulation).
(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.
(c) These Clauses apply to the processing of personal data as specified in Annex II.
(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.
(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.
(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.
(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679, 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.
(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 or in a way that prejudices the fundamental rights or freedoms of the data subjects.
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.
(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.
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.
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 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. 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) GENERAL WRITTEN AUTHORISATION: 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 30 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.
(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.
(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 of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.
(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:
(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.
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 of Regulation (EU) 2016/679, 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) of Regulation (EU) 2016/679, shall be stated in the controller's notification, and must at least include:
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 of 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.
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.
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.
(a) Without prejudice to any provisions of Regulation (EU) 2016/679, 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:
(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.
Controller: you as the customer. The details from the main contract apply; within the product they are taken from your organisation data (company, address, contact person). Your acceptance of this agreement is recorded with timestamp, version and acting person, and takes the place of the signature under Annex I of the template.
Processor:
| | | |---|---| | Company | RevEx Solutions GmbH | | Address | Schmalholzstrasse 11/1, 88048 Friedrichshafen, Germany | | Commercial register | Local Court of Ulm, HRB 749378 | | VAT ID | DE453596612 | | Managing Directors | Andreas Burger, Sven Nagel | | Contact for data protection matters | [email protected] | | Data Protection Officer | not currently appointed | | Activity | Provision of the ImperIQ platform as software as a service |
Subject matter: provision and operation of the ImperIQ platform including the modules and solutions booked by the customer.
Duration: the term of the main contract, plus statutory retention periods (in particular under commercial and tax law; for financial records up to ten years).
Nature and purpose: storage, evaluation, display and processing of data entered or uploaded by the customer in order to provide the respective module function; automated evaluation by AI functions where used by the customer.
Categories of data subjects
| Category | Context | |---|---| | The customer's staff | User accounts, roles, time tracking, HR master data | | Contacts at the customer's customers and suppliers | Business partner management, procurement, sales | | Recipients of invoices and records | Finance module | | Recipients of messages and campaigns | Marketing module, in each case consent-based | | Whistleblowers | Whistleblowing system |
Categories of personal data
| Category | Examples | |---|---| | Master data | Name, address, contact details, function | | Contract and business data | Quotes, orders, invoices, payments, records | | Employee data | Role, responsibility, working hours, project assignment | | Communication data | Email traffic via the platform, records of consent | | Usage data | Logins, logs, edit history | | Input to AI functions | Free text, uploaded documents and images |
Sensitive data (Article 9 GDPR): the platform is not intended for the processing of special categories of personal data. The general terms and conditions prohibit the controller from entering such data, and no instruction to that effect exists.
One exception concerns the whistleblowing system under the German Whistleblower Protection Act. Reports are captured there as free text whose content the processor can neither prescribe nor screen in advance; in addition there are details of persons involved and attached files. By the nature of the procedure, a report may contain information falling under Article 9. The processor therefore applies the specific restrictions set out in Annex III to this area — strict purpose limitation, access only for expressly named persons, logging of every access, and the confidentiality of the reporting person's identity required by the procedure.
Structured according to the template. The entries describe the state of the system.
| # | Measure per template | Implementation by the processor |
|---|---|---|
| 1 | Pseudonymisation and encryption | Transport encryption TLS 1.2+; encryption of data at rest; passwords are stored exclusively as hashes, never in plain text or reversibly encrypted |
| 2 | Confidentiality, integrity, availability, resilience | Tenant separation is enforced by the database (row-level security on all business tables, with FORCE in production); the application connects with restricted privileges and cannot bypass the separation |
| 3 | Restoring availability after an incident | Automated backups with regular restore testing; documented disaster recovery plan |
| 4 | Regular testing of effectiveness | Automated checks in the delivery pipeline that block regressions; every check reports its own scope; a register of checks with demonstrated fault detection |
| 5 | User identification and authorisation | Role and permission system enforced server-side at every interface; multi-factor authentication; invitation and revocation procedures. For the whistleblowing system additionally: access only for expressly named persons, every access is logged, and the reporting person's identity remains protected |
| 6 | Protection during transmission | TLS 1.2+ with strong cipher suites; upstream protection against denial-of-service attacks |
| 7 | Protection during storage | Encryption at rest; storage exclusively in German data centres (Nuremberg, Falkenstein) |
| 8 | Physical security of processing locations | Operated at Hetzner Online GmbH, Germany; their access and site security applies via the data processing agreement in place there |
| 9 | Event logging | Tamper-evident log with cryptographic chaining (SHA-256); subsequent alteration is detected; the chain is verified automatically every day |
| 10 | System configuration | Deployment exclusively through automated, traceable procedures; changes to production require approval and are logged |
| 11 | Internal IT and IT security governance | Documented development and release processes; four-eyes principle for security-relevant changes; dependency and code review |
| 12 | Certification and quality assurance | No ISO 27001 or SOC 2 certification at present. The measures are aligned with these frameworks but are not externally certified |
| 13 | Data minimisation | Transmission to AI service providers takes place without user or organisation identifiers; depictions of persons are technically blocked in the image generator |
| 14 | Data quality | Central master data management with conflict protection for concurrent editing; provenance record for every change |
| 15 | Limited retention | Expiry periods and access restrictions are set with the provider for generated media |
| 16 | Accountability | Record of processing activities within the product; complete change log; documented procedures for access and erasure requests |
| 17 | Portability and erasure | Export in common formats; erasure across all dependent data stores, tested and logged in live operation. After the contract ends, data remains available for the retrieval period agreed in the provider-switching annex to the terms and conditions before erasure; erasure is certified |
Assistance to the controller (Clause 8(d) and Clause 9): the processor assists the controller with access, rectification and erasure requests from data subjects through the functions provided in the product and on request. In the event of a personal data breach, the processor provides the information listed in Clause 9.2 without undue delay and names a contact point.
Maintained on the basis of Clause 7.7(a) (general authorisation). The template does not require this annex where general authorisation applies — we maintain it voluntarily so that you see the list in the contract and not only on a website.
Change procedure: the processor informs you at least 30 days before the change takes effect, in text form. You may object within 14 days of receipt. Where the service cannot be provided without the sub-processor concerned, either party may terminate the affected service.
List as of 17 August 2026. The version in force is available within the product.
| No. | Name and location | Processing activity | Location | |---|---|---|---| | 1 | Hetzner Online GmbH, Germany | Operation of application, database, object storage, backups, event service | Nuremberg / Falkenstein, DE | | 2 | Anthropic PBC, USA | Language models for analysis and assistance functions | USA | | 3 | Mistral AI SAS, France | Language models and embeddings | EU | | 4 | OpenAI OpCo LLC, USA | Language models and embeddings, where selected | USA | | 5 | Features & Labels, Inc. (fal.ai), USA | Image generation in the Marketing Studio | USA | | 6 | Stripe, Inc. / Stripe Payments Europe Ltd. | Billing and payment processing | USA / IE | | 7 | Sinch Germany GmbH (Mailjet) | Sending of emails, notifications and invoices | EU | | 8 | Cloudflare, Inc., USA | DNS, transport encryption, attack mitigation | USA | | 9 | Functional Software, Inc. (Sentry), USA | Error diagnostics — processing in the EU region | EU region | | 10 | GitHub, Inc. / Microsoft, USA | Sign-in via GitHub, where chosen by the user | USA | | 11 | Google LLC, USA | Sign-in via Google, where chosen by the user | USA |
Third country transfers: for the recipients located in the USA (nos. 2, 4, 5, 6, 8, 10, 11) the transfer takes place on the basis of the standard contractual clauses under Implementing Decision (EU) 2021/914. The basis applicable to each recipient and the corresponding evidence are available within the product under Settings → Compliance & Legal.
Source of the Clauses. Clauses 1 to 10 are reproduced from the Annex to Commission Implementing Decision (EU) 2021/915 (OJ L 199, 7.6.2021, p. 18–30), English language version, retrieved via EUR-Lex on 27 August 2026. Only the places the template provides for completion have been filled in; the wording of the Clauses is otherwise unchanged.