Data Processing Terms

Last updated: 19 October 2026

These terms form part of the Terms of Service between you ("Controller" / "Data Fiduciary") and Zappila ("Processor"). They apply to personal data in your workspace ("Customer Data").

1. Scope

We process Customer Data only to provide the Service, following your documented instructions (your use of the workspace and these terms). Categories of people: your affiliates, advertisers, employees and website visitors whose clicks are tracked. Categories of data: names, contact details, payout details, IP addresses, device and browser information, click and conversion records and any custom fields you create.

2. Our duties

• Process Customer Data only on your instructions, unless the law requires otherwise.
• Keep it confidential and make sure our staff who can access it are bound by confidentiality.
• Apply the security measures described on our Security page.
• Help you answer requests from people exercising their rights, and with security and breach duties, taking into account the nature of processing.
• Tell you without undue delay after we become aware of a personal data breach affecting your Customer Data.
• Delete or return Customer Data when your workspace is closed and the export period ends, unless the law requires us to keep it.
• Allow reasonable audits by you on request, once a year, at your cost and with notice, in a way that does not expose other customers.

3. Your duties

You are responsible for the lawfulness of the data you collect and for giving your users the notices and obtaining the consents the law requires, including for tracking cookies and click IDs.

4. Sub-processors

You allow us to use sub-processors such as hosting, backup, email delivery and payment providers. We choose them with care, bind them to terms no less protective than these, and remain responsible for them. We will tell you of significant changes to this list, and you may object on reasonable data-protection grounds.

5. Transfers

Where Customer Data is moved to another country we make sure the transfer is allowed by the law that applies to it.

6. Contact

Data protection requests and questions: [email protected].