1. Parties and scope

This Data Processing Agreement (“DPA”) supplements the agreement under which [Customer legal name and address] (“Customer”) receives QueryBolt services from Vistra Nova Ltd, company number 17056517, of 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ (“QueryBolt”).

This DPA applies only where QueryBolt processes Customer Personal Data on Customer’s behalf in providing the service. QueryBolt remains an independent controller for data it processes for its own account administration, billing, fraud prevention, legal compliance and direct customer relationship, as described in the Privacy Policy.

If this DPA conflicts with the main service agreement on personal-data processing, this DPA controls to the extent of that conflict. Capitalised data-protection terms have the meanings given by applicable Data Protection Law.

2. Customer instructions

Customer instructs QueryBolt to process Customer Personal Data only as necessary to provide, secure, support and improve the contracted QueryBolt service, and as further documented in the agreement, product configuration and lawful written instructions.

QueryBolt will inform Customer if, in its reasonable opinion, an instruction infringes applicable Data Protection Law, unless legally prohibited from doing so. QueryBolt may suspend the affected processing while the parties resolve an unlawful or technically unsafe instruction.

3. Processor obligations

To the extent required by applicable Data Protection Law, QueryBolt will:

1. process Customer Personal Data only on documented instructions, including for international transfers, unless required by law;
2. ensure people authorised to process Customer Personal Data are subject to appropriate confidentiality obligations;
3. implement and maintain technical and organisational measures appropriate to the processing risk;
4. taking account of the nature of processing, provide reasonable assistance for data-subject requests, security obligations, breach notifications, impact assessments and regulator consultations;
5. notify Customer without undue delay after confirming a Personal Data Breach affecting Customer Personal Data, and provide available information reasonably needed for Customer’s notification duties;
6. maintain information necessary to demonstrate compliance and support reasonable audits under section 9; and
7. delete or return Customer Personal Data at the end of the service, at Customer’s choice, except where law requires retention or data remains temporarily in protected backup cycles.

4. Customer responsibilities

Customer is responsible for the lawfulness, accuracy and minimisation of Customer Personal Data and its instructions. Customer will provide required notices, establish a lawful basis, honour data-subject rights, and avoid submitting data that is unnecessary for SQL optimization.

QueryBolt is not designed for special-category data, payment-card data, government identifiers, health records, or production secrets. Customer must not submit those categories unless the parties first agree in writing on scope and additional safeguards.

5. Technical and organisational measures

QueryBolt maintains measures appropriate to the service and processing risk, including:

• HTTPS/TLS for customer traffic and configured encryption at rest for production database storage and backups;
• bcrypt password hashing, expiring sessions, CSRF protection, security headers, request limits and rate limiting;
• customer-scoped application access and audited administrative mutations;
• per-job temporary benchmark databases, constrained runtime database permissions and scheduled cleanup;
• secrets stored outside source control and restricted production deployment paths;
• automated tests, dependency management, code review, health checks and error monitoring; and
• data export, account deletion, customer-controlled query history and scheduled retention pruning.

The current public description is maintained at querybolt.io/security. QueryBolt may update measures without materially reducing the overall protection of Customer Personal Data.

6. Subprocessors

Customer gives general authorisation for QueryBolt to use subprocessors needed to provide the service. The current provider register is at querybolt.io/subprocessors and forms Annex 3 of this template.

QueryBolt will impose data-protection obligations appropriate to each subprocessor’s processing. Material additions or replacements will be published on the provider register. Any specific advance-notice period or objection procedure must be recorded in the executed DPA or main agreement.

If Customer reasonably objects to a new subprocessor on documented data-protection grounds, the parties will work in good faith on a commercially reasonable alternative. If no alternative is available, either party may terminate the affected service subject to the main agreement.

7. International transfers

Each party will use a lawful transfer mechanism where Customer Personal Data is transferred to a country without an applicable adequacy decision. Depending on Customer location and processing, the execution copy may incorporate the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum.

The parties must identify the applicable SCC module, competent supervisory authority, governing member-state law and UK Addendum selections before execution. Provider-specific safeguards remain governed by the relevant provider terms and DPA.

8. Data-subject and government requests

If QueryBolt receives a request relating to Customer Personal Data, it will direct the requester to Customer where appropriate and will not respond on Customer’s behalf unless instructed or legally required. QueryBolt will provide reasonable assistance based on the nature of processing.

Where legally permitted, QueryBolt will notify Customer of a binding government request for Customer Personal Data and will disclose only the information legally required.

9. Information and audits

QueryBolt will first satisfy reasonable compliance enquiries using current documentation, provider reports and written responses. If that information is insufficient, Customer may request one audit per year on reasonable written notice, during normal business hours, subject to confidentiality and security restrictions.

Audits must avoid access to other customers’ data, source-code secrets, penetration-test exploit details and systems unrelated to Customer processing. Customer bears its audit costs unless the audit identifies a material breach by QueryBolt.

10. Term, liability and governing terms

This DPA begins on the effective date in the execution copy and continues while QueryBolt processes Customer Personal Data. Liability, governing law and dispute terms follow the main agreement unless mandatory Data Protection Law requires otherwise.

No limitation excludes liability that cannot lawfully be limited. Amendments must be agreed in writing by authorised representatives, except updates expressly permitted by this DPA.

Annex 1 — Processing details

Annex 2 — Security measures

The measures in section 5 and the current Security & Trust page describe the baseline controls. The execution copy may attach additional account-specific measures where agreed.

Annex 3 — Provider register

The current register at querybolt.io/subprocessors identifies core, conditional and independently controlled services. The parties should attach or archive a dated copy when executing this DPA.

• Amazon Web Services (AWS): Core hosting infrastructure — Processor; core infrastructure.
• Sinch Mailgun: Transactional email — Processor; conditional.
• Stripe: Payments and subscription management — Processor and independent controller, depending on the activity; conditional.
• Sentry: Error monitoring — Processor; conditional.
• PostHog: Server-side product analytics — Processor; conditional.
• Google: Web font delivery, optional Google sign-in and reCAPTCHA — Independent service provider and processor, depending on the activity; Always active for web fonts; sign-in and reCAPTCHA conditional.
• GitHub: Optional GitHub sign-in — Third-party identity provider; conditional.
• Cloudflare: DNS, public asset delivery and optional edge proxying — Processor and network service provider, depending on the activity; cdnjs assets requested by shared-layout pages; edge proxy conditional.

Signatures

Complete only in the execution copy agreed by both parties.