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Legal

Data Processing Addendum

1. Scope & roles

This Addendum applies where, in providing the managed cloud, [Company Legal Name] (“Processor”) processes personal data on behalf of a customer (“Controller”) that is subject to applicable data protection law (e.g. the GDPR/UK GDPR). The Controller determines the purposes and means; the Processor processes only as described here and on the Controller’s documented instructions.

2. Definitions

“Personal data”, “processing”, “data subject”, “controller”, “processor” and “supervisory authority” have the meanings in applicable data protection law. “Customer personal data” means personal data within customer content processed under the Terms.

3. Processing on instructions

The Processor will process customer personal data only on the Controller’s documented instructions (including via configuration of the Service), unless required by law, in which case it will inform the Controller unless prohibited. The Controller is responsible for the accuracy and lawfulness of its instructions and its right to provide the data.

4. Confidentiality

The Processor ensures personnel authorized to process customer personal data are bound by confidentiality and process it only as instructed.

5. Security measures

The Processor implements appropriate technical and organizational measures to protect customer personal data, as described in Annex II, taking into account the state of the art, costs, and the risks of processing.

6. Sub-processing

The Controller grants general authorization for the Processor to engage sub-processors listed in Annex III to provide the Service. The Processor imposes data-protection obligations on sub-processors no less protective than this Addendum and remains responsible for their performance. The Processor will give notice of intended changes and a reasonable opportunity to object.

7. Data-subject requests

Taking into account the nature of the processing, the Processor will assist the Controller by appropriate technical and organizational measures, and to the extent the Service permits, to respond to data-subject requests. Requests received directly will be referred to the Controller.

8. Personal-data breaches

The Processor will notify the Controller without undue delay after becoming aware of a personal-data breach affecting customer personal data, and will provide information reasonably available to help the Controller meet its notification duties.

9. DPIA assistance

The Processor will provide reasonable assistance to the Controller with data-protection impact assessments and prior consultations with supervisory authorities, taking into account the information available to the Processor.

10. International transfers

Where the Processor transfers customer personal data across borders subject to transfer restrictions, it will rely on an appropriate mechanism, such as the EU Standard Contractual Clauses (Module Two: controller-to-processor) and, for the UK, the IDTA or UK Addendum, which are incorporated by reference where applicable.

11. Deletion or return

On termination, the Processor will, at the Controller’s choice, delete or return customer personal data and delete existing copies, unless law requires storage. Backups are deleted on their normal cycle.

12. Audits & information

The Processor will make available information reasonably necessary to demonstrate compliance and allow for and contribute to audits, including inspections, conducted by the Controller or an authorized auditor, subject to reasonable notice, confidentiality, and frequency limits, and may satisfy audit rights via third-party reports where available.

13. Liability & term

Each party’s liability under this Addendum is subject to the limitations and exclusions in the Terms. This Addendum takes effect when incorporated and continues for as long as the Processor processes customer personal data. If it conflicts with the Terms on data protection, this Addendum controls.

Annex I — Details of processing

A. Parties

Controller: the customer. Processor: Mapwright.

B. Description

  • Data subjects: the Controller’s end users and personnel.
  • Categories of data: account identifiers, API keys, request data (which may include coordinates and search terms), and usage data.
  • Special categories: none intended; the Controller must not submit special-category data except as expressly agreed.
  • Frequency: continuous, for the term.
  • Nature & purpose: hosting and operating the Service to provide map, geocoding, routing and related functionality.
  • Duration: the term, plus deletion per §11.

C. Competent supervisory authority

As applicable to the Controller or its EU representative.

Annex II — Technical & organizational measures

Area Measure
EncryptionTLS for data in transit; encryption at rest for stored data
Access controlLeast-privilege access, unique credentials, MFA for admin access
Network securitySegmentation, firewalls, restricted management interfaces
Logging & monitoringAudit logs and monitoring for security-relevant events
ResilienceBackups and recovery procedures for the managed service
Secure developmentCode review, dependency management, change control
PersonnelConfidentiality obligations and security awareness
Incident responseDocumented procedures to detect, respond and notify

Measures may evolve as the Service develops, provided protection is not materially reduced. See our Security page.

Annex III — Sub-processors

Provider Purpose Location
Amazon Web ServicesHosting & computeus-east-1
Amazon CloudFrontContent delivery / edge cacheGlobal edge