Is a Data Processor and do you offer a Data Processing Agreement?

At, we decide what data we collect from users and the purpose of processing. This, according to the definitions in GDPR, defines us as a Data Controller, and not a Data Processor with regards to our users. It is therefore not relevant for us to offer a Data Processing Agreement to individual customers. 

This is clearly defined in GDPR Article 1 "Definitions" 
point 7:‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

point 8: processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Since our FREE and PRO plans are only offered to individuals and we do not enter into a corporate commercial agreement where your company instruct us to process personal information for you, every individual user of will be the data subject in the case where they sign up for an account with us, the Data Controller. A Data Processor is someone who only processes data on the Data Controller's requests and instructions, and within strictly defined purposes, e.g. a hosting provider. 

Our Privacy Policy states the following: 

"This policy applies where we are acting as a Data Controller with respect to the personal data of users of our Services; in other words, where we determine the purposes and means of the processing of that personal data. For content and data that you upload to or make available through the Service (“User Content”), you are responsible for ensuring this content is in accordance with our Terms of Service, and that the content is not violating other users’ privacy."

Regarding information that you choose to upload or share through, our Terms of Service state: 

"You are responsible for your use of the, including the lawfulness of any content displayed, shared, uploaded or otherwise made available by you in the Service (“the User Content”). User Content includes room names, and you are responsible for ensuring room names does not include Prohibited User Content (as listed below). Your room names are used to construct the the URLs identifying your rooms, and guests you invite and other third parties can (request to) enter your rooms based on these URLs. As these guests do not need to authenticate to in order to do this, please be aware that room names must be considered public information. Do not include information that you do not want to make public in room names."

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