# Data processing agreement

URL: https://briq.cloud/legal/dpa

> The Article 28 terms under which briq processes personal data on your behalf, including sub-processors and security measures.

Last updated: 7 October 2026.

This agreement is part of the [terms of service](https://briq.cloud/legal/terms) and applies when you accept them;
**no signature is needed**. If you need a countersigned copy, write to
[privacy@briq.cloud](mailto:privacy@briq.cloud).

## 1. Roles

You are the **controller** of personal data that you or your agents place in your briqs, send to
our API or store on volumes; briq (Uplab SAS) is the **processor**. If you are yourself a processor,
we are your sub-processor on the same terms. Your own account data is covered by the
[privacy notice](https://briq.cloud/legal/privacy), not here.

## 2. Our obligations (Art. 28(3))

1. **Instructions**: we process only on your documented instructions, which are your use of the
   API, MCP tools and dashboard, including your choice of region. We tell you if an instruction
   seems to breach the GDPR, or if the law requires other processing, unless the law forbids it.
2. **Confidentiality**: everyone with access is bound to it.
3. **Security**: we keep the measures in Annex II (Art. 32).
4. **Sub-processors**: only under section 3.
5. **Data subject requests**: you can reach your data directly; where you need more, we assist.
6. **Breaches and assessments**: we notify you **within 48 hours** of becoming aware of a breach
   affecting your data, including one a sub-processor reports to us, and help with security, impact assessments and prior consultation
   (Arts. 32–36).
7. **End of processing**: destroying a briq destroys its machine and volume; when your account
   closes, remaining data is deleted within 30 days, unless the law requires otherwise; copies in
   our sub-processors' backups expire on their own schedules.
8. **Audits**: we give you the information needed to verify this agreement, starting with this
   page, the [security model](https://briq.cloud/docs/security) and [data protection](https://briq.cloud/legal/data-protection), and
   allow one audit a year (more where the law requires), at reasonable notice and without
   compromising other customers.

## 3. Sub-processors

You authorise the sub-processors in Annex III. They are bound by obligations as protective as these,
and we remain liable for them. We publish any addition or replacement here and email account holders
**at least 30 days before** it takes effect. Changes our sub-processors make to their own
sub-processors are passed on as soon as they notify us. If you object on reasonable data protection grounds and
we cannot resolve it, you may terminate the affected service and we refund unused prepaid credits.

## 4. Transfers outside the EU

Your briqs, volumes and logs are processed in your team's region. Paris (the default) is in the EU;
choosing another region is your instruction to transfer data there. briq's control plane runs in
Amsterdam.

Our sub-processors' parent companies are incorporated in the United States, so US law could in
principle reach them wherever the data sits. Any transfer or access relies on the EU–US Data Privacy
Framework or, failing that, the Standard Contractual Clauses, with the measures in Annex II. We
review these safeguards, tell you if we find them ineffective, and challenge any government request
that appears unlawful or overbroad, telling you unless the law forbids it.

## 5. Term and liability

This agreement lasts as long as we process personal data for you. Liability follows the
[terms of service](https://briq.cloud/legal/terms); on data protection, this agreement prevails over them.

***

## Annex I — the processing

|                                     |                                                                                                               |
| ----------------------------------- | ------------------------------------------------------------------------------------------------------------- |
| **Subject matter and purpose**      | Running container images as isolated microVMs, with the storage, networking, logging and metering around them |
| **Duration**                        | While you have an account; for each briq, until it is destroyed                                               |
| **Nature**                          | Execution, storage, transmission and deletion of whatever you place in a briq                                 |
| **Personal data and data subjects** | Determined by you (typically your users, customers or staff); briq neither requires nor inspects it           |
| **Special categories**              | Not expected; tell us before processing Article 9 or 10 data                                                  |

## Annex II — security measures

| Area           | Measure                                                                                                        |
| -------------- | -------------------------------------------------------------------------------------------------------------- |
| Isolation      | One Firecracker microVM per briq, no shared kernel; one private network per team                               |
| Network        | Private by default; no inbound traffic until you expose a port; SMTP prohibited by policy                      |
| Secrets        | Secret values write-only and masked in status, logs and audit; API keys and agent tokens stored as hashes only |
| Encryption     | TLS for all API, MCP and dashboard traffic; provider encryption at rest for volumes and databases              |
| Access control | Team roles (owner, admin, member); per-key limits on concurrency, size, registry, TTL and spend                |
| Logging        | One audit row per authenticated request: key, action, target, duration, calling client                         |
| Deletion       | Destroying a briq destroys its machine and volume; logs are not kept after destroy                             |
| Operations     | Operator access limited to running the service; administrative actions are audited                             |
| Resilience     | Machine lifecycle runs in background jobs; a reconciler enforces TTLs and removes orphans every 10 seconds     |

## Annex III — sub-processors

| Sub-processor           | Purpose                                                                                    | Location                                         | Transfer safeguard                                |
| ----------------------- | ------------------------------------------------------------------------------------------ | ------------------------------------------------ | ------------------------------------------------- |
| Infrastructure provider | Compute, volumes and logs of your briqs                                                    | Your team's region (Paris by default); US parent | Data Privacy Framework and SCCs for any US access |
| Hosting provider        | briq's control plane: API, dashboard and the database holding briq metadata and audit rows | Amsterdam, Netherlands; US parent                | Data Privacy Framework and SCCs for any US access |

We name each sub-processor on request, for your transfer assessment or an objection under section 3:
[privacy@briq.cloud](mailto:privacy@briq.cloud).