Data Processing Agreement
Last updated: January 1, 2026
Introduction
This Data Processing Agreement ("DPA") forms part of the agreement between Stubborn Coder, S.L. ("Processor") and the customer ("Controller") for the use of vDocs. It governs the processing of personal data by us on your behalf in accordance with the EU General Data Protection Regulation (GDPR). This DPA is incorporated into the Terms of Service; by accepting those Terms or using the Service you agree to it, and no separate signature is required.
Roles of the Parties
For personal data you submit to the Service, you act as the Controller and we act as the Processor. We process such data only on your documented instructions, including with regard to international transfers, unless required otherwise by applicable law.
Scope and Purpose of Processing
The processing we carry out on your behalf includes:
- Nature: storage, analysis, and transformation of uploaded video and related content into documentation.
- Purpose: providing, maintaining, and supporting the Service.
- Duration: for the term of your subscription and any retention period thereafter.
- Categories of data: account identifiers (name and email), uploaded video and related content, generated documentation, and usage metadata.
Our Obligations
As Processor, we will:
- Process personal data only on your documented instructions.
- Ensure personnel authorized to process data are bound by confidentiality.
- Implement appropriate technical and organizational security measures.
- Assist you in responding to data subject requests and regulatory obligations.
- Delete or return personal data at the end of the engagement, as instructed.
Subprocessors
You authorize us to engage subprocessors to support the Service. We remain responsible for their compliance with this DPA and impose data protection obligations on each. We currently rely on the following categories of subprocessors:
AI video and language model providers — analysis of uploaded video and generation of documentation. These providers may process data in the United States under Standard Contractual Clauses.
Cloud hosting and storage provider — operation of the Service and storage of content.
Authentication and database provider — account identity and data storage.
Payment processor — subscription billing and related charges.
Transactional email provider — account and service-related email.
We will provide advance notice of any intended changes to our subprocessors and give you the opportunity to object. A current list is available on request at info@vdocs.ai.
International Transfers
Where personal data is transferred outside the European Economic Area, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses.
Personal Data Breach
We will notify you without undue delay after becoming aware of a personal data breach affecting your data, and provide information reasonably required to help you meet your notification obligations.
Audits
We will make available information reasonably necessary to demonstrate compliance with this DPA and allow for audits as required by applicable law. Any audit is limited to once in any twelve-month period, requires at least 30 days' prior written notice, takes place during business hours, is subject to confidentiality, and is carried out at the requesting party's expense.
Contact
For questions about this DPA or to request our current subprocessor list, email info@vdocs.ai.