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DPA

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Data Processing Agreement (DPA)

GalGom Solutions, SL, with its registered office at Calle Aribau, 170 1º2ª, 08036 Barcelona, Spain, and VAT number B01961291 (hereinafter referred to as the “Data Processor” or “GalGom Solutions”).

  1. Purpose

    2. This Data Processing Agreement (DPA) governs the terms under which GalGom Solutions will process personal data on behalf of the Client in relation to the services provided through Click Fraud Free.

  2. Purpose and Nature of Processing

    3. GalGom Solutions will process personal data to manage, optimize, and report the performance of advertising campaigns on Google Ads. This includes but is not limited to:

    • The collection of Google Ads data.
    • Campaign optimization.
    • Performance reporting.
  3. Duration

    4. This DPA will remain in effect for the duration of the contractual relationship between GalGom Solutions and the Client and while personal data is processed.

  4. Types of Personal Data Processed
    • Contact Data: Name, email address.
    • Payment Data: Credit card or other payment method details (via external providers).
    • Account Data: Client’s Google Ads account information, including identifiers and settings.
  5. Obligations of the Data Processor

    6. 5.1 Processing According to Instructions

    • GalGom Solutions will process personal data only in accordance with the Client’s instructions.

    5.2 Confidentiality

    • All personnel with access to personal data will sign a confidentiality agreement.

    5.3 Security Measures

    • GalGom Solutions will implement and maintain appropriate technical and organizational measures to protect personal data from unauthorized access, loss, or destruction, including encryption, access controls, and physical and logical security.
  6. Sub-Processors

    7. By using the service, the Client authorizes GalGom Solutions to engage necessary sub-processors to fulfill the contractual obligations. Current sub-processors include payment providers (currently Stripe and PayPal), hosting providers (currently IONOS), and others as necessary. Sub-processors may be replaced or supplemented, with notice provided to the Client for their information.

  7. Rights of Data Subjects

    8. GalGom Solutions will facilitate the exercise of data subjects’ rights, including access, rectification, erasure, and data portability, upon the Client’s request. Requests will be addressed within 30 days.

  8. Data Deletion or Return

    9. Upon termination of the contractual relationship, GalGom Solutions will delete or return all personal data processed, unless legally required to retain it.

  9. Audits and Assessments

    10. The Client has the right to request audits to verify compliance with this DPA, with a minimum notice of 30 days. Audits must be conducted without disrupting operations and at the Client’s expense.

  10. Notification of Security Incidents

    11. GalGom Solutions will notify the Client of any security incidents affecting personal data within 24 hours of detection. This notification will include:

    • The nature of the breach.
    • The affected data.
    • Actions taken to mitigate damage and prevent future incidents.