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SvenskaGDPR Art. 28 Standard Agreement
B2B Data Processing

Data Processing Addendum (DPA)

This Data Processing Addendum ("DPA") is entered into between the Customer ("Data Controller") and Softstuff AB, reg. no. 559271-4744 ("Data Processor" or "Washproof"), forming an integral part of the General Terms of Service. This DPA governs the processing of personal data in accordance with Article 28 of the General Data Protection Regulation (EU GDPR 2016/679).

Role Allocation & Governance Structure

Customer = Data Controller You determine the purposes and means of processing and retain full ownership of all accounting entries, vouchers, and personal data uploaded.
Softstuff AB (Washproof) = Data Processor We process personal data solely on your documented instructions to provide the Service and generate your climate and sustainability reports.

1. Subject Matter and Duration of Processing

The Processor (Softstuff AB, reg. no. 559271-4744) shall process personal data on behalf of the Controller (Customer) solely to perform and provide the Service for the duration of the Customer's active subscription or service agreement and in accordance with the configured audit retention window for reporting.

2. Categories of Data Subjects and Personal Data

  • Categories of Data Subjects: Customer employees, consultants, corporate signatories, and third-party supplier contacts.
  • Types of Personal Data: Names, work emails, contact phone numbers, job titles, and details contained in transaction records and supplier invoices (e.g. contact persons and authorizers).

3. Technical and Organizational Measures (TOMs)

The Processor implements and maintains appropriate technical and organizational safeguards pursuant to Article 32 of the GDPR:

End-to-End Encryption:

All data in transit is encrypted using modern TLS 1.3, and all data at rest is encrypted using AES-256 within Google Cloud.

Access Control & IAM:

Strict Principle of Least Privilege, scoped IAM service accounts, and mandatory MFA for all engineering personnel.

Geographical Boundary:

All production databases, cold storage, and compute instances are strictly locked to EU regions (europe-west1).

Audit Logging & Backup:

Automated daily incremental backups with point-in-time recovery and append-only audit logging for administrative actions.

4. Sub-processors

The Controller hereby grants the Processor a general written authorization to engage sub-processors for cloud hosting and core integrations (Google Cloud Platform, Fortnox AB). The Processor ensures that all sub-processors are bound by equivalent data protection obligations as set forth in this DPA.

5. Security Breach Management & Collaboration

Upon confirming a Personal Data Breach, the Processor shall notify the Controller in writing without undue delay and at the latest within 48 hours of becoming aware of the incident, assisting the Controller in fulfilling its statutory reporting obligations to supervisory authorities (such as IMY).

6. Deletion and Return of Personal Data

(a) Raw Data & Audit Retention Window: When creating a report, the Customer configures an audit retention window (1 or 3 months). Upon expiry of this window, the Processor automatically purges underlying voucher files, invoice texts, and personal data in accordance with GDPR data minimization principles. Finalized report aggregates and Voucher IDs (voucherId, ledger accounts, transaction amounts, and calculated emissions) are retained permanently as an audit trail, enabling the Customer and its financial auditors to cross-reference and verify figures directly against the Customer's primary accounting records. Following raw data purging, new report versions cannot be generated from raw inputs.

(b) Termination: Upon termination of the Service, the Processor shall, at the choice of the Controller, delete or return all remaining personal data within ninety (90) days, unless European Union or Swedish national law mandates ongoing retention.

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