Template — have counsel review before launch. Jurisdiction-specific terms and the cross-border transfer mechanism are marked below as items for counsel to complete.

Data Processing Agreement

Last updated: June 29, 2026

1. Roles

For data you submit to UTM Drift Guard (the “Customer Data”), you act as the data controller and Peakure LLC (“we”) act as the data processor. We process Customer Data only to provide the Service and on your documented instructions.

2. Scope of processing

The subject matter is UTM audit and governance. We process the marketing parameter data and account details you provide for the duration of your subscription. We do not sell Customer Data or use it to train third-party models.

3. Subprocessors

You authorize our use of the subprocessors listed on our Subprocessors page. We remain responsible for their performance and will notify you of material changes.

4. Security

We maintain technical and organizational measures appropriate to the risk, including encryption in transit, row-level access controls on tenant data, and least-privilege access. See our Security page.

5. Data subject rights

We will assist you in responding to data-subject access, correction, and deletion requests. You can export or delete account data from your settings, or contact us for help. See Your Data Rights.

6. International transfers

Where Customer Data of EU/UK data subjects is transferred to the United States or other jurisdictions, the transfer relies on the European Commission’s Standard Contractual Clauses (SCCs) and, for UK data, the UK International Data Transfer Addendum, together with supplementary safeguards as appropriate.

7. Governing terms

This DPA forms part of and is governed by our Terms of Service. It is governed by the laws of the State of New York, United States, and the parties submit to the exclusive jurisdiction of the courts located in New York. Legal notices may be sent to Peakure LLC, New York, United States, or to support@utmdriftguard.com.

Request a signed DPA

Need a countersigned copy for your records? Email support@utmdriftguard.com.

    Data Processing Agreement — UTM Drift Guard