Data Processing Addendum

Parties and scope

This addendum forms part of the service terms between the workspace customer (“Customer”, controller) and Kevin Tuyizere, operating Trylane in Rwanda (“Processor”). It applies only to personal data processed on the Customer’s documented instructions to provide Trylane. Trylane’s own account, billing, support and security controller processing is described separately in the Privacy Policy. If the Customer acts as a processor, it confirms authority from its controller to appoint Trylane as a subprocessor.

Subject matter: temporary demo lifecycle and access management. Duration: the service relationship plus necessary cleanup and applicable retention. Nature: receiving configuration, authenticating scoped access, recording lifecycle commands, transmitting instructions to customer agents, recording limited milestones, supporting export and deletion. Purpose: provide the requested demo management service.

Processing details and instructions

The Customer determines the purposes and lawful basis, supplies required notices, obtains any required permissions and maintains secure applications and authorized instructions. We process only documented instructions, including for transfers, unless law requires otherwise; where permitted we inform the Customer of such a requirement. We promptly notify the Customer if an instruction appears to infringe applicable data-protection law and may suspend that instruction pending resolution.

Confidentiality and safeguards

Access is limited to authorized people with confidentiality obligations. Safeguards include scoped role checks, hashed project keys, signed and replay-limited SDK requests, one-use handoffs, short-lived visitor access, fixed generation/expiry checks, bounded commands and cleanup acknowledgment before metadata deletion. Customer-side PostgreSQL row isolation and side-effect guards must be correctly implemented and operated by the Customer.

Production deployment must use HTTPS, private database connections, restricted credentials, backups and appropriate provider access controls. Security measures evolve with risk and technology without materially reducing overall protection. The Security page describes scope and limitations, rather than an independent audit or certification.

Subprocessors and transfers

The Customer generally authorizes the service subprocessors listed on our provider page for their stated functions. Independent controllers for payment or optional website analytics are distinguished there. We impose appropriate confidentiality, security and data-protection obligations on subprocessors and remain responsible for their performance of our processor obligations.

We give at least 30 days’ advance notice of a planned new or replacement subprocessor through account email or an in-service notice. The Customer may object on reasonable data-protection grounds by contacting privacy@trylane.app during that period. We seek a reasonable solution; if none is available, the affected processing may be terminated with repayment of unused prepaid service where applicable.

International transfers require an applicable lawful mechanism and required Rwanda authorizations. This addendum does not itself execute European, UK or Rwanda standard contractual clauses or appoint a representative. Where additional clauses or assessments are required for the actual processing, they must be completed before the affected transfer.

Assistance, incidents and audit

Considering the processing and information available to us, we assist with individual rights requests, security obligations, breach notifications, impact assessments and regulator consultations. We refer requests concerning Customer-controlled data to the Customer rather than independently changing its instructions, unless law requires otherwise.

We notify the Customer without undue delay after becoming aware of a personal data breach affecting its processor data, provide available information about the nature, affected categories, likely consequences, mitigation and contact point, and supplement it as facts develop. This does not replace the Customer’s own reporting obligations or applicable statutory deadlines.

We make available information reasonably necessary to demonstrate compliance and permit proportionate audits by the Customer or an independent confidential auditor, including inspections where legally required. Audit arrangements protect other customers and service security and do not improperly restrict a regulator’s powers. Any reasonable assistance fees must be agreed in advance and cannot prevent legally required cooperation.

Return, deletion and end of service

The Customer can export workspace records and request deletion through Settings. Access is revoked first; customer agents must finish resource cleanup before control-plane metadata is purged. The Customer keeps its agent operating and remains responsible for its separately hosted application rows and resource tombstones.

At the Customer’s choice, we return or delete processor data at the end of services, except data that law requires to be retained. Restricted backup copies expire under their documented backup schedule and are protected from ordinary use; a restore must reapply deletion instructions. The retention schedule and recovery dependencies are set out in the Privacy Policy. Independent controller records are governed by their separate lawful purposes.

This addendum prevails over conflicting service terms on processor data protection. It does not reduce rights or obligations imposed by applicable law.