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Legal

Data Processing Agreement (DPA)

Version 1.0 – effective 27 Oct 2026

On this page
  1. between the Organizer (Controller) and DYNAMIC BTL EVENTS SRL, operating Eventyora (Processor)
  2. 1. Parties and definitions
  3. 2. Subject matter, duration and nature
  4. 3. Types of data and data subjects
  5. 4. Processor obligations (art. 28(3))
  6. 5. Organizer obligations
  7. 6. Subprocessors
  8. 7. International transfers
  9. 8. Data subject requests
  10. 9. Audits
  11. 10. Personal data breach
  12. 11. End of the contract
  13. 12. Liability, law and order of documents
  14. 13. Signatures
  15. Annex 1: Subprocessors
  16. Annex 2: Technical and organisational measures (TOM)

between the Organizer (Controller) and DYNAMIC BTL EVENTS SRL, operating Eventyora (Processor)

1. Parties and definitions

Terms such as "personal data", "processing", "data subject" and "personal data breach" have the meaning in Regulation (EU) 2016/679 (GDPR).
This DPA is part of the Terms of Service. If they conflict on personal data, this DPA prevails.

2. Subject matter, duration and nature

Eventyora processes personal data for the Organizer to provide the Eventyora services (CRM, Experience, Production and the mobile apps) for as long as the contract lasts, plus the period needed to return or delete the data (clause 11).
Nature and purpose: hosting, storing, organising, displaying, transmitting by email and notification, and deleting data so that the Organizer can sell tickets, send invitations, check guests in, communicate with guests, handle offers, contracts, invoices and payments, and show live screens.

3. Types of data and data subjects

4. Processor obligations (art. 28(3))

Eventyora will:
a) process personal data only on documented instructions from the Organizer (this DPA, the Terms and the Organizer's use of the features), unless EU or Romanian law requires otherwise (in which case it informs the Organizer first, if allowed);
b) make sure everyone who handles the data is bound by confidentiality;
c) apply the security measures in Annex 2;
d) respect the conditions for subprocessors in clause 6;
e) help the Organizer answer data subject requests, using the tools in the product and reasonable support;
f) help the Organizer with security, breach notification, impact assessments and prior consultation (art. 32-36);
g) delete or return the data at the end (clause 11);
h) give the Organizer the information needed to show compliance, and allow audits (clause 9);
i) tell the Organizer if, in its view, an instruction breaches the GDPR.

5. Organizer obligations

The Organizer: has a valid legal basis and gives the notices for the data it loads; asks sensitive questions (art. 9) only with a valid basis, usually explicit consent; manages its users' roles and access; and gives lawful instructions.

6. Subprocessors

The Organizer gives general authorisation for the subprocessors in Annex 1 (also on the public Subprocessors page). Eventyora will tell Organizers at least 30 days before adding or replacing one (by email and on the page). The Organizer may object on reasonable data protection grounds within that time (write to privacy@eventyora.com); if not solved, the Organizer may end the affected service. Eventyora signs with each subprocessor a contract with equivalent obligations and remains responsible for it.

7. International transfers

Data is hosted in the EU/EEA. Where a subprocessor transfers data outside the EEA, it does so under an adequacy decision (for example the EU-US Data Privacy Framework) or Standard Contractual Clauses (Annex 1 shows which).

8. Data subject requests

If Eventyora receives a request that concerns the Organizer's data, it forwards it to the Organizer without undue delay and does not answer it itself, unless instructed.

9. Audits

Eventyora provides, on request, its security documentation and answers to the Organizer's security questionnaire. Once a year, or after a breach, with 30 days' notice, during working hours and without harming other clients, the Organizer (or an independent auditor bound by confidentiality) may audit Eventyora's compliance with this DPA. Costs are the Organizer's, unless the audit finds serious non-compliance.

10. Personal data breach

Eventyora informs the Organizer without undue delay and in any case within 48 hours after becoming aware of a breach that affects the Organizer's data, with the information it has: what happened, the data and people affected, likely consequences, measures taken, and a contact (privacy@eventyora.com). Eventyora keeps updating the Organizer. The Organizer decides on notifying ANSPDCP (within 72 hours) and the data subjects. See the Breach Notification Procedure.

11. End of the contract

At the end, Eventyora lets the Organizer export its data for 30 days. After that Eventyora deletes or anonymises the data within 60 days and from backups on their normal cycle, unless the law requires keeping it. Eventyora confirms deletion in writing on request. The Data Retention Policy applies.

12. Liability, law and order of documents

Liability follows the Terms of Service. Romanian law applies; the courts of Bucharest Sector 2 decide. Order of priority: this DPA, then the Terms.

13. Signatures

Accepted electronically by the Customer on sign-up; for Eventyora: DYNAMIC BTL EVENTS SRL, Andrei Rădulescu, Administrator.


Annex 1: Subprocessors

See the Subprocessors page (/legal/subprocessors) – it is part of this annex.

Annex 2: Technical and organisational measures (TOM)

Status is as at 26 October 2026. "Yes" means implemented and tested locally; "Partial" and "No" are shown honestly.

AreaMeasureStatus
Access controlRole-based permissions (owner, agency admin, organizer admin, client organizer, event manager, viewer, check-in, finance, DJ), checked at organization AND event level on every requestYes
Tenant separationOne organizer cannot read another's data; tested with a second organizer and injected IDs (403)Yes
AuthenticationPassword hashes; login throttle (5 attempts / 15 min); equal response time and message for unknown users; session ID regenerated on login, reset and remember-me; remember-me cookie signed and invalidated on password resetYes
Two-factor sign-inFor organizer accounts: not available. Only the platform admin panel has TOTPNo (planned)
Encryption in transitHTTPS with redirect; cookies Secure, HttpOnly, SameSite=Lax. HSTS prepared, not yet switched on livePartial
Encryption at restConnector secrets are encrypted. Personal data in the database and backups is not encrypted at field level; the host's disk protection appliesNo (planned)
PaymentsCards never stored; payment notifications from Netopia verified by RSA signature, issuer, expiry and amount; shop webhooks signed with HMAC and replay protectionYes
Public and door linksRandom tokens (16-32 bytes), no search indexing, no referrer, key re-checked on every scanYes
UploadsSVG refused, images re-encoded, type checked, random file namesYes
EmailFixed sender domain with SPF, DKIM and DMARC (reject); one-click unsubscribe on marketing mail; sender cannot be spoofed by organizersYes
Error handlingGeneric error messages with a reference ID; no technical details to usersYes
Audit logSensitive writes (tickets, payments, deletions) are logged. Every download of a participant, report or payments list and every collaborator guest CSV writes an audit line (who, which event, when) since 26 Oct 2026. Screen views of lists are not loggedYes (exports); views not logged
Abuse limitsRate limits on login and recovery; password-reset and verification-email sending limited per IP and per mailbox (since 26 Oct 2026)Yes
Browser security headersX-Frame-Options, X-Content-Type-Options, Referrer-Policy present; Content-Security-Policy not yet on livePartial
Data minimisation and deletionAnswers of people who started a ticket but never paid are erased automatically 30 days after the event (running since 26 Oct 2026); account deletion in the profile; deletion tooling reviewed and rehearsedYes
BackupsBackups taken before changes and on a schedule; encrypted backups and a restore test are not yet provenPartial
Change controlEvery change is reviewed by an internal critic, a break-tester and a security reviewer on a test copy with no real data before release; releases keep a rollback packageYes
StaffAccess to production limited to named staff; confidentiality dutiesYes (organisational)
Vulnerability managementInternal review per release; no external program or written patch SLA yetPartial
Incident responseWritten breach notification procedure, available on requestYes (written)