--- title: "Data processor and sub-processors" description: "When CLAQON acts as a processor of your data, what the data processing agreement under Article 28 of the GDPR covers and which sub-processors are involved." url: https://claqon.com/en/legal/data-processing/ language: en updated: 2026-10-13 alternates: es: https://claqon.com/legal/encargado-del-tratamiento/ pt: https://claqon.com/pt/legal/operador-de-dados/ --- Legal # Data processor and sub-processors CLAQON runs on your machine and processes your data there. We only access it when you ask us for remote support or the done-for-you setup, always on your behalf and under a data processing agreement. In force since 13 October 2026 Updated on 13 October 2026 Planned terms for when CLAQON goes on sale. Today the website only takes pre-registrations: it does not sell or charge anything. If you do sign up, we will give you the contract before you sign, and that contract is what will bind you. Courtesy translation: in case of discrepancy, the Spanish version prevails. [Español](https://claqon.com/legal/encargado-del-tratamiento/) This page explains when the owner of CLAQON acts as a processor of its customers’ data, within the meaning of Article 28 of the General Data Protection Regulation (GDPR), what the corresponding agreement covers and which providers are involved. ## Your installation processes your data on your machine CLAQON is installed on your machine or on a server rented in your name. Your accounts and connections, your keys, your scripts, your videos, your metrics and any personal data you process with it stay there, for example the data of the people who appear in your material. - **It does not reach us.** Your installation connects directly to the platforms and providers you configure, with your own keys and apps. - **You are the controller.** Your company is responsible for that data, as the controller. We neither receive it nor use it. - **Licence telemetry is a different matter.** If your installation uses a licence issued by the owner, it sends a short technical report, without content or keys. We carry out that processing as controller, and it is explained in the [privacy policy](https://claqon.com/en/legal/privacy/#licencias). ## When we act as a processor Only when we need to access your installation to help you: - during **remote support**, if you ask us to go in to solve a problem; - during the **done-for-you setup** and the start-up of the pilot, which we carry out via a remote session. In those cases we process the data on your behalf, following your instructions and only for that purpose. **Without a signed data processing agreement, there is no remote access.** - **Each session, authorised in writing.** Before each remote session, you tell us by email what you need us to do. You open the session yourself, from your machine, and you can end it at any time. When it is over, we tell you in writing what we did. - **Reports you send us by email.** If you only write to us or send us a support report, we do not access your installation. We process what you send us as controller, in order to assist you, in accordance with the [privacy policy](https://claqon.com/en/legal/privacy/#soporte). If the report contains third-party data, such as that of your audience, we use it only to resolve your query and delete it when the query is closed. ## What the agreement covers The data processing agreement is signed together with the main contract and lasts as long as the pilot or the licence. It follows the Spanish Data Protection Agency (AEPD) guidelines on contracts between controllers and processors, and covers at least what Article 28(3) of the GDPR requires: - **Subject matter and purpose.** Remote support and start-up of your CLAQON installation. - **Data we may access.** Whatever is in your installation: connected accounts, settings, production and error logs, and support reports, which do not include keys. - **Data subjects.** Your company’s contact persons, the people who appear in your material and your audience, to the extent that their data is in your installation. - **Only on your instructions.** We process the data only on your documented instructions. - **Confidentiality.** The people who have access are bound by a duty of confidentiality. - **Security.** We access remotely without copying your keys outside your installation, with measures appropriate to the risk. - **Sub-processors.** Only those on the closed list below, and we will notify you before any change. - **Help with rights and breaches.** We help you respond to people exercising their rights and manage security breaches that affect your data. - **On termination.** We return or delete the data according to your instructions. If you end the pilot, we help you uninstall and export your data. - **No use for our own purposes.** We do not use your data to train models or to improve the product, unless we agree to it in a separate contract. - **No hosting.** We do not host your installation or operate your server. Remote access is one-off and for the agreed task. - **Audits.** We give you the information needed to demonstrate that we comply, and we accept reasonable audits, notified 30 days in advance, at most once a year unless there is a breach or an authority requests one. - **No international transfers.** We do not take your data outside the European Economic Area. If that ever became necessary, it would only be with your prior written authorisation and with the safeguards of Chapter V of the GDPR. ## Sub-processors The sub-processors involved in support, such as email or the remote session tool, will be listed in the data processing agreement, with their location and safeguards. We will notify you before any change and you will be able to object. The providers of this website, which do not process the data of your installation, are listed in the [privacy policy](https://claqon.com/en/legal/privacy/#destinatarios). ## Your responsibilities as controller - **Your privacy policy.** If you connect YouTube or other platforms, your installation needs its own privacy policy and terms, with your details as the owner. We are preparing templates for this. - **The legal basis for what you publish.** Holding the rights and the legal basis to process the data of the people who appear in your videos. - **The instructions.** Telling us in writing what we may do in each support session. - **Revocation.** You can withdraw the permissions you gave your apps at any time from the security settings of your Google account or of each platform. If you have any questions, write to soporte@claqon.com.