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Data processing agreement

Version 1 · effective 15 October 2026 · All versions · This is the current version

This data processing agreement ("DPA") is part of the Terms of Service and applies to every organisation account (Terms, section 4). It is concluded between the organisation that holds the account ("Customer") and Eureka.legal, Denmark ("Eureka").

1. Roles

2. Subject matter, duration, nature and purpose

The processing is described in Annex 1. It lasts as long as the organisation account exists and until the Customer Data has been deleted or returned under section 9.

3. Instructions

Eureka processes Customer Data only on the Customer's documented instructions. The Terms, this DPA, the configuration of the organisation account by its administrators and the use of the Service by the members are the Customer's instructions. Eureka informs the Customer without delay if, in its opinion, an instruction infringes the GDPR or other data protection law. Eureka processes Customer Data outside the instructions only where EU or Member State law requires it, and then tells the Customer of that requirement before processing, unless the law forbids it.

4. Confidentiality

Everyone Eureka authorises to process Customer Data is bound by confidentiality, by contract or by law, and has access only as far as needed to provide the Service.

5. Security

Eureka implements the technical and organisational measures of Annex 2, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks for the rights and freedoms of natural persons (GDPR article 32). Eureka may improve the measures over time as long as the level of protection does not fall.

6. Sub-processors

The Customer authorises Eureka to engage the sub-processors listed in Annex 3. Eureka imposes on each sub-processor, by contract, data protection obligations equivalent to this DPA and remains responsible to the Customer for the sub-processor's performance. Eureka announces an intended addition or replacement of a sub-processor at least 30 days before it takes effect, by a new version of this DPA (see all versions) and by e-mail to the organisation's administrators. The Customer may object on reasonable data protection grounds within those 30 days; if the parties find no solution, the Customer may end the organisation account with immediate effect and is refunded the unused part of any prepaid period.

7. Assistance to the Customer

8. Information and audits

Eureka makes available the information necessary to demonstrate compliance with article 28 GDPR: this DPA, Annex 2 and, on request, a description of the hosting and the processing. The Customer, or an auditor it mandates who is not a competitor of Eureka, may audit the processing at most once a year, or after a personal data breach, with at least 30 days' notice, during business hours and without disturbing the Service; the parties agree on scope and method in advance. Each party bears its own costs; where the audit shows no material non-compliance, the Customer bears Eureka's reasonable costs.

9. Deletion and return

When the organisation account ends, the Customer's administrators can remove the members; each member keeps a private account unless they delete it. On the Customer's request, made within 30 days after the account ends, Eureka provides an export of the Customer Data (members, follows and notifications) in a machine-readable form and deletes the Customer Data that Eureka does not need to keep under EU or Member State law. What remains afterwards is the pseudonymous history described in the privacy policy, which no longer points at a person or at the Customer.

10. Where the data is processed

Customer Data is stored and processed in the European Union (Annex 3). Eureka engages a sub-processor outside the European Economic Area only where Annex 3 says so, and then only in a country for which the European Commission has decided that the protection is adequate.

11. Liability, term and precedence

Liability under this DPA follows the Terms. This DPA applies for as long as the organisation account exists and until section 9 has been carried out. Changes to this DPA are published as new versions in the same way as changes to the Terms (Terms, section 14), and the Customer's continued use of the organisation account after a new version applies constitutes its acceptance; a change of sub-processor follows section 6. Where this DPA and the Terms conflict, this DPA prevails for the processing of Customer Data. This DPA is governed by the laws of Denmark and the courts of Denmark have jurisdiction, as in the Terms.

Annex 1: the processing

Subject matterProviding the Service to the Customer's members: the extension on EUR-Lex, the reader on eureka.legal, follows, notifications and e-mail alerts, under the organisation account.
NatureStorage, retrieval, display, e-mail delivery, pseudonymous usage recording, deletion.
PurposeLetting the members read EU legislation with Eureka's features and receive news about the acts they follow; letting the Customer's administrators manage seats and members.
Categories of data subjectsThe Customer's employees and other persons the Customer admits to the organisation account; the Customer's administrators.
Categories of personal dataE-mail address; organisation membership and role (administrator or member); plan; e-mail alert settings; the acts and articles a member follows and the notifications about them; connected browsers (install id, when added, last seen); the acts, languages and parts a member reads and the usage events in the Service, under the install id or account number; the articles a member shares; request logs (time, address, answer, install id or account number, user agent, IP address, shortened after 30 days).
Special categoriesNone are needed by the Service. The Customer instructs its members not to enter any in free-text fields (feedback, contact form).
DurationSection 2 and section 9; retention as in the privacy policy.

Annex 2: technical and organisational measures

Annex 3: sub-processors

Sub-processorPurposeDataLocation and safeguard
Hetzner Online GmbHHosting of the Eureka service, its database, the visitor statistics and the websiteAll Customer DataGermany (EU)
Porkbun LLCE-mail delivery: sign-in links and e-mail alertsRecipient e-mail address and the content of the messageUnited States. Being replaced by a provider in the European Union or in a country with an adequacy decision; the replacement is announced as in section 6.
Anthropic, PBCAI evaluations of acts (translation notices, timeline entries, summaries of changes, corrigenda verdicts)None: receives the published text of acts and, when a search for an act finds nothing, the text of that search, which members are instructed not to fill with personal data; no Customer Data. Listed for transparency.United States

When paid plans start, the payment provider will be added here in a new version of this DPA, with the 30 days' notice of section 6, before any payment is taken.