XYnovaethrix
Data Processing Addendum (DPA)
Effective Date: 31 December 2025
Scope: Applies to all XYnovaethrix services, platforms, applications, APIs, and any processing of personal data worldwide.
Authority Hierarchy: Internal Constitution → Privacy Policy → Data Processing Addendum → Related Agreements
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1️⃣ PURPOSE
This Data Processing Addendum governs the processing of personal data by XYnovaethrix on behalf of its users, customers, partners, developers, and licensees. It ensures compliance with global data protection laws including GDPR, CCPA, and applicable regional regulations.
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2️⃣ DEFINITIONS
1. Data Controller: Entity that determines the purposes and means of personal data processing. 2. Data Processor: XYnovaethrix, acting on behalf of the Data Controller. 3. Personal Data: Any information relating to an identified or identifiable individual. 4. Processing: Any operation performed on Personal Data, including collection, storage, use, transfer, or deletion.
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3️⃣ SCOPE OF PROCESSING
1. XYnovaethrix will process personal data strictly to deliver, operate, and improve its services. 2. Categories of data include: - Account information (name, email, login credentials) - Usage data (logs, analytics, activity within services) - Payment and transaction information (if applicable) - Educational or developer data (for licensed users) 3. Processing is limited to purposes defined in the associated agreements (e.g., Terms of Service, Developer License, Educational License).
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4️⃣ OBLIGATIONS OF XYNOVAETHRIX
1. Process data lawfully, fairly, and transparently. 2. Implement appropriate technical and organizational measures to protect personal data. 3. Only engage sub-processors with prior notification and agreement. 4. Assist Data Controllers in fulfilling obligations (e.g., data subject rights, breach notification). 5. Maintain records of processing activities. 6. Delete or return personal data upon termination or expiration of services, unless legally required to retain.
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5️⃣ DATA SUBJECT RIGHTS
1. Users may exercise rights including: - Access and correction of personal data - Data portability - Restriction or objection to processing - Erasure (right to be forgotten) where applicable 2. XYnovaethrix will facilitate these rights in cooperation with Data Controllers.
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6️⃣ SECURITY AND CONFIDENTIALITY
1. Implement encryption, access controls, monitoring, and incident response. 2. Maintain confidentiality of personal data and limit access to authorized personnel. 3. Report data breaches promptly to the Data Controller and authorities as required.
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7️⃣ INTERNATIONAL DATA TRANSFERS
1. Transfers outside of the origin jurisdiction are conducted under compliant legal mechanisms (e.g., Standard Contractual Clauses, adequacy decisions). 2. Ensure equivalent protection levels for personal data in all transfers.
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8️⃣ SUB-PROCESSORS
1. XYnovaethrix may engage trusted sub-processors. 2. Notify Data Controllers prior to onboarding new sub-processors. 3. Sub-processors must comply with equivalent data protection standards.
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9️⃣ AUDIT RIGHTS
1. Data Controllers may audit or request evidence of compliance. 2. XYnovaethrix will provide reasonable access to records, reports, and controls, respecting confidentiality and security.
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10️⃣ LIABILITY
1. XYnovaethrix is responsible for breaches arising from negligence or non-compliance. 2. Liability limitations are as defined in underlying agreements.
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11️⃣ TERM AND TERMINATION
1. DPA remains effective for the duration of the underlying service agreement. 2. Obligations regarding personal data survival post-termination remain in force.
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12️⃣ AMENDMENTS
- XYnovaethrix may update the DPA to maintain legal compliance. - Updates take effect upon posting. - Controllers and processors are responsible for reviewing and adhering to the latest version.
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13️⃣ CONTACT
For questions, clarifications, or data protection requests, contact:
Email: dpa@xynovaethrix.org Portal: https://xynovaethrix.org/dpa Phone: +000-000-0000
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Version: DPA-1.0
Status: Active
Scope: Global – all entities, services, platforms, APIs, and digital operations of XYnovaethrix involving personal data processing