Data Processing Agreement

What we process, and why

Subject and purpose: storing and showing the information the Company records in Kelunor to organise its work — shifts, absences and cover, the organigram and duties, tasks, announcements, chat and files — for as long as the Company uses Kelunor.

People concerned: the Company's employees, collaborators or volunteers, with or without a Kelunor account.

Data: names, the e-mail or phone number the Company enters for people without an account, roles and functions, shifts, absences (dates and type, without the reason unless the Company writes one), tasks and messages. The Company should not record special categories of data (for example health details) unless it has a legal basis and it is necessary.

The Company's responsibilities

Decide what is recorded and have a legal basis for it (for example the employment contract or a legitimate interest), and tell its people that Kelunor is used and how (it can point them to kelunor.com/privacy).

Give admin rights only to people who need them, and answer its people's requests to see, correct or delete their data — we help with that.

Our commitments

We process the data only to provide Kelunor and on the Company's documented instructions — which are the settings and actions of its admins in the app — unless the law requires otherwise, in which case we tell the Company first where allowed.

Only the people who run Kelunor can access the service's systems, they are bound by confidentiality, and they never read content as a routine; end-to-end encrypted content cannot be read by us at all.

We keep appropriate security measures: encryption in transit and at rest, optional end-to-end encryption, access rules tested automatically, protection against automated abuse, redundant storage and error monitoring (details at kelunor.com/security).

We help the Company respond to its people's requests and meet its obligations on security, breach notification and impact assessments, with the information we have.

If we become aware of a personal data breach affecting the Company's data, we tell it without undue delay, with what we know and what we are doing about it.

We make available the information needed to show we comply with this agreement and answer reasonable questions and audits, with reasonable notice and at the Company's cost beyond the usual.

Sub-processors and location

We use Google Cloud / Firebase (Google Ireland Ltd. and its affiliates) for hosting, database, file storage, sign-in, server functions and notifications, with data stored in the European Union (europe-west1, Belgium); Google reCAPTCHA Enterprise against automated abuse; and the push services of Google, Apple and Mozilla to deliver notifications without content.

Google bound itself to data-protection terms equivalent to these; where data could be accessed from outside the EU, the EU Standard Contractual Clauses or the EU–US Data Privacy Framework apply. We will tell the Company about new sub-processors at least 30 days in advance on this page, and the Company may object by stopping using the service.

End of the agreement

When the Company deletes its company space, or its account is deleted, we delete the Company's data from the service, and from any backups within 30 days, unless the law requires us to keep something. Before that, the Company's admins can download what they need.

This agreement lasts as long as the Company uses Kelunor for its people. It is part of the Terms of use (kelunor.com/terms) and is governed by the same law.