Data Processing Agreement (Art. 28 GDPR)
Last updated 24 October 2026
Draft — pending legal review before public launch.
This agreement applies between the account holder (“Controller”) and Becker Films, [address] (“Processor”), as operator of linktogallery. It is accepted by the account admin when the account is created.
1. Subject and duration
The Processor provides gallery pages for Google Drive folders chosen by the Controller, for as long as the account exists.
2. Data and data subjects
- Team members: email address, role, join date.
- Gallery data: settings, project numbers, and references to Drive folders (stored encrypted).
- Content in shared folders (photos, videos, file names) is not stored by the Processor; it is read from Google Drive when a gallery is viewed and cached for a short time only.
3. Instructions and confidentiality
The Processor processes data only to run the service and on documented instructions of the Controller. Everyone with administrative access is bound to confidentiality. Customer galleries are not accessed except on the Controller’s request, e.g. for support.
4. Technical and organisational measures
- Drive folder references encrypted (AES-256-GCM); the key is held separately from the database.
- Database encrypted at rest; access controlled by row-level security per account.
- No passwords: sign-in by one-time codes sent to the verified email address.
- Administrative access limited to few people, with two-factor authentication.
- Hosting in the EU (database: Frankfurt).
5. Sub-processors
- Supabase (database, authentication) — EU region
- Vercel (hosting)
- Resend (sign-in emails)
- Google (Drive API, delivery of the shared media)
6. Rights of data subjects, deletion
The Processor supports the Controller in answering data subject requests. When an account or gallery is deleted, its data is removed from the database; Drive folders remain untouched.