Compliance · DPA

Data Processing Agreement.

Standard DPA template covering GDPR (EU 2016/679) and LGPD (Brazil 13.709/2018). Eight clauses, plain language, written for legal review without surprises. Request a signed copy bound to your MSA via the email below — typical turnaround 3 business days.

What the standard DPA covers

Subject matter & purpose

TheoCloud processes Customer Data on behalf of the Customer to provide the deploy, build, observability, and runtime services. No secondary use, no aggregation across tenants.

Duration of processing

For the term of the subscription. On termination: Customer-initiated export within 30 days, then verifiable deletion within 60 days.

Categories of data

Application logs, runtime metrics, configuration (theo.yaml), deployment metadata (commit SHA, branch, author). Customer Data inside the application is processed by the Customer, not by Theo.

Sub-processors

Listed publicly with location, role, and DPA status. 30-day advance notice on additions; objection window. Current list available on request and reviewed quarterly.

International transfers

Customer-selectable region (EU, US, BR roadmap). Standard Contractual Clauses (SCC 2021/914) for any cross-border processing. No transfers to jurisdictions without adequacy.

Security measures (Annex II)

Encryption at rest (AES-256) and in transit (TLS 1.3+). Per-tenant isolation. Audit logs with 1-year retention. Annual penetration test. Incident response within 24h for confirmed breaches.

Audit & inspection rights

Annual SOC 2 Type II report provided under NDA on the audit cadence published with prospective Enterprise customers. Customer-led audit allowed once per year with reasonable notice. No-cost questionnaire response within 30 days.

Breach notification

Notification to Customer DPO within 24 hours of confirmed breach. Includes nature, affected categories, impact assessment, remediation timeline.

Compliance posture

GDPR + LGPD aligned

DPA template covers GDPR (EU 2016/679), LGPD (Lei 13.709/2018), and UK GDPR. Brazilian customers get LGPD-specific language for ANPD requirements.

Audit-ready by design

Signed image provenance, immutable audit logs, per-tenant SBOM, every deploy traceable to a commit SHA + human approver.

Standard documents

DPA (this template), MSA (master subscription agreement), SLA (uptime + response), SOC 2 Type II report (under NDA when available).

Operational evidence stack: DPA + audit logs + SBOM + signed images. SOC 2 Type II audit cadence shared with prospective Enterprise customers under NDA.