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Data Processing Agreement

Last Updated: April 10, 2026

Purpose

This Data Processing Agreement (DPA) sets out the terms for the processing of personal data by Spark901 on behalf of our users and partner organizations.

Processing Obligations

Spark901 will process personal data only in accordance with the documented instructions of the data controller and for the purposes of providing our services.

Confidentiality

We ensure that persons authorized to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

Security

Spark901 implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk of data processing.

Sub-processors

We use certain sub-processors to assist in our processing activities, such as data hosting and payment processing. We maintain a list of all sub-processors and will provide notice of any changes.

This document is for informational purposes and provides baseline legal protections. It is recommended that this document be reviewed by professional legal counsel to ensure it meets your specific organizational needs and complies with all local regulations.