Business Data Processing Agreement
The current Article 28 working terms for business customers using Hermes Platform as a processor.
Effective 10 July 2026 · Policy 2026-07-10.v1 · Draft pending counsel review
Parties and scope
This DPA applies where Links Academy EOOD, UIC 208651214, processes personal data on behalf of the business customer identified in an order form. The customer acts as controller or authorized processor; independent controller activities remain governed by the Privacy Notice.
Instructions and use
Customer data is processed only to operate, secure, support and delete the managed agent and connected services under the agreement and documented customer instructions. It is not sold, used for advertising or used to train platform-owned models.
Confidentiality and security
Authorized personnel are bound by confidentiality and receive least-privilege access. Human content access is denied by default and exceptional access requires authorization, time limitation and audit. Current measures are described in the Security and Retention pages.
Subprocessors and transfers
The customer gives general authorization for the published subprocessors. New subprocessor notice and a reasonable objection process will follow the final agreement. Transfers outside the EEA require an applicable adequacy decision, contractual clauses or another lawful safeguard.
Rights and incidents
Links Academy EOOD provides reasonable assistance with data-subject rights, DPIAs and security obligations and notifies the customer without undue delay after becoming aware of a personal-data breach affecting customer data.
Deletion and audits
Active tenant data and credentials are deleted on the documented workflow, subject to bounded backups and separately retained legal records. Reasonable compliance evidence is available without exposing other tenants or security-sensitive information.
Contract status
This page is a working summary, not a signed DPA. Customer/order-form details, notice period, audit terms, transfer annexes, liability and signatures require the final business agreement and counsel approval. Contact info@links.academy.