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Legal

Data Processing Agreement

Version 2.2 · Article 28 UK GDPR Compliant

1. Parties

Data Controller: The customer or entity that uses Endorsr and determines the purposes and means of processing personal data.

Data Processor: BuiltByGo Ltd, operating Endorsr (endorsr.co), registered in England and Wales.

2. Scope

This DPA governs the processing of personal data by the Processor on behalf of the Controller in connection with the Endorsr platform. It forms part of the Terms of Service and applies to all personal data processed through the platform.

3. Processing Details

Subject matter: Athlete and brand account management, deal matching, payment processing, and platform operations.
Duration: The term of the Controller's account, plus retention periods required by law.
Nature and purpose: Providing the Endorsr athlete endorsement marketplace platform.
Categories of data subjects: Athletes, brand representatives, fans, and platform visitors.
Types of personal data: Names, email addresses, profile information, payment metadata, device tokens, and usage analytics.

4. Controller Obligations

The Controller warrants that they have obtained all necessary consents and have a lawful basis for processing personal data through the platform. The Controller is responsible for the accuracy and legality of the data they submit.

5. Processor Obligations

The Processor shall:

  • Process personal data only on documented instructions from the Controller
  • Ensure personnel are subject to appropriate confidentiality obligations
  • Implement appropriate technical and organisational security measures
  • Not engage sub-processors without prior authorisation (see Schedule 2)
  • Assist the Controller in fulfilling data subject rights requests
  • Notify the Controller without undue delay of any personal data breach
  • Delete or return all personal data at the end of the service term

6. Sub-Processors

The Controller authorises the Processor to engage the sub-processors listed in Schedule 2. The Processor shall provide at least 14 days notice of any intended changes to this list.

7. Data Subject Rights

The Processor shall assist the Controller in responding to data subject access requests, rectification requests, erasure requests, and other rights under UK GDPR. Requests can be sent to [email protected].

8. Data Breach Notification

The Processor shall notify the Controller within 48 hours of becoming aware of a personal data breach. The notification shall include the nature of the breach, categories of data affected, and remedial measures taken or proposed.

9. Governing Law

This DPA is governed by the laws of England and Wales. Any disputes shall be subject to the exclusive jurisdiction of the courts of England and Wales.

Schedule 1: Security Measures

Data at rest: AES-256 encryption for all database and storage data.

Data in transit: TLS 1.3 for all network communications.

Access control: Row-level security enforced at database level. Service roles restricted to edge functions only.

Authentication: Multi-factor authentication available. Session management via Supabase Auth with configurable expiry.

Audit logging: Immutable, append-only audit log for all content review and administrative actions.

Infrastructure: Hosted on Supabase (Google Cloud Platform, US regions) and Cloudflare (global edge network).

Schedule 2: Sub-Processors

NameServiceLocation
SupabaseDatabase, Auth, Edge FunctionsUS (GCP)
StripePayment processingUS / EU
CloudinaryImage hostingUS (AWS)
MuxVideo streamingUS / EU
CloudflareCDN, DNS, WorkersGlobal edge
RailwayWeb application hostingUS
ResendEmail deliveryUS / EU
PostHogProduct analytics (self-hosted)US
SentryError monitoringUS

Note: Stripe, Sentry, and Railway are conditional sub-processors — only engaged if the Controller uses the relevant features.

Schedule 3: Controller Rights

This DPA does not limit the Controller's rights under UK GDPR or the Data Protection Act 2018. The Controller may request an audit of the Processor's compliance upon 30 days written notice, subject to confidentiality obligations and reasonable security restrictions.