Data Processing Agreement (DPA) – BlitzFin

Please note: the German version (AVV) is the legally binding one. Part A below is the official English language version of the EU standard contractual clauses; Part B and the Annexes are a convenience translation.

Version of October 2, 2026

Preamble and scope

1. This data processing agreement (“DPA”) applies between the customer who has concluded a contract with us for the use of the BlitzFin platform (“usage contract”), as controller, and blue media labs GmbH, Am Isenbrink 2a, 30926 Seelze, Germany, as processor.
2. Under section 9 of our terms and conditions, the DPA forms part of the usage contract. It is concluded electronically (Art. 28(9) GDPR); no separate signature is required. On request we provide a version signed by us as a PDF.
3. The DPA consists of Part A (standard contractual clauses of the European Commission under Art. 28(7) GDPR, Implementing Decision (EU) 2021/915), Part B (supplementary provisions) and Annexes I to IV. In the event of a contradiction, Part A prevails (Clause 4).
4. Data processing agreements signed separately with individual customers remain in force until the parties agree on this version.

Part A – Standard contractual clauses

Section I

Clause 1 – Purpose and scope

(a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

(b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.

(c) These Clauses apply to the processing of personal data as specified in Annex II.

(d) Annexes I to IV are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2 – Invariability of the Clauses

(a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3 – Interpretation

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4 – Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5 – Optional

Not agreed.

Section II – Obligations of the Parties

Clause 6 – Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7 – Obligations of the Parties

7.1. Instructions

(a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing

(a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

7.6. Documentation and compliance

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7. Use of sub-processors

(a) GENERAL WRITTEN AUTHORISATION: The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 14 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

(e) The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8. International transfers

(a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8 – Assistance to the controller

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions

(c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

1. the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;
2. the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;
3. the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;
4. the obligations in Article 32 of Regulation (EU) 2016/679.

(d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9 – Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

(b) in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller’s notification, and must at least include:

1. the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
2. the likely consequences of the personal data breach;
3. the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c) in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

Section III – Final provisions

Clause 10 – Non-compliance with the Clauses and termination

(a) Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

1. the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;
2. the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;
3. the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

(d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

Part B – Supplementary provisions

The following provisions supplement Part A within the meaning of Clause 2(b). They do not contradict Part A; in case of doubt, Part A applies.

B.1 Instructions (re Clause 7.1)

The controller's instructions are documented in the usage contract, in this DPA and through the use and configuration of the platform (e.g. creating project rooms, inviting users, uploading, approving and deleting documents). The controller gives further instructions in text form (e.g. by email to info@blitzfin.com).

B.2 Information about sub-processors (re Clause 7.7)

1. The agreed list of sub-processors is Annex IV; it is also published at blitzfin.com/subprocessors/.
2. Information about intended changes is given in text form by email to the address of the account owner or organization administrators stored in the account. This satisfies the written form within the meaning of Clause 7.7(a).
3. The controller may object to a change in text form within the period under Clause 7.7(a). The parties will then look for a solution together. If no agreement is reached, the controller may terminate the usage contract as of the date on which the new sub-processor is to be engaged.

B.3 Evidence and audits (re Clause 7.6)

The processor demonstrates compliance primarily through information and suitable documents, such as certificates and audit reports of its sub-processors. The controller announces on-site inspections with notice of, as a rule, at least 14 days; they take place during normal business hours, without disproportionately disrupting operations, and while preserving confidentiality toward other customers. A mandated auditor must be bound to confidentiality and must not be a competitor of the processor. Where there are indications of non-compliance, no notice periods apply.

B.4 Delimitation: processing under own responsibility

This DPA does not cover processing that the processor carries out as a controller in its own right and describes in its privacy policy. This concerns in particular the management of user accounts and login, contract handling and billing, the security of the platform, and statistics on the use of features (e.g. which features are used how often). The processor does not use the content of project rooms and documents for these purposes.

B.5 AI features

1. Where the platform reads documents with the help of an AI language model (see Annexes II and IV), this is done solely to provide the respective feature to the controller. The results are suggestions; review and approval remain with the users.
2. Neither the processor nor its sub-processors use the controller's data to train or fine-tune AI models. One customer's content is not used for other customers.
3. New or changed features are tested with the controller's data only on its documented instruction in the individual case (text form suffices).

B.6 Breach notification (re Clause 9.2)

The processor notifies breaches without undue delay, where possible within 48 hours after becoming aware of them, by email to the address of the account owner or organization administrators stored in the account.

B.7 Term, return and deletion (re Clause 10)

1. The DPA applies for the term of the usage contract and beyond for as long as the processor processes the controller's data – including read access after project completion under section 6 of the terms and conditions.
2. Data is returned via the platform's export function. Deletion follows section 6 of the terms and conditions; the controller can also delete project rooms and documents itself at any time. Copies in backups are deleted as part of the regular backup cycle.

B.8 Liability and final provisions

Liability is governed by the usage contract, unless Part A provides otherwise. Amendments to this DPA require text form; the processor notifies the controller of adjustments to the Annexes that do not lower the level of protection. Otherwise, the final provisions of the terms and conditions (section 13) apply.

Annex I – List of parties

Controller

The customer under the usage contract, with the name and address details stored there or in the account.
Contact person: the account owner or organization administrators, with the email address stored in the account; where applicable, the data protection officer named by the customer.
Accession: by concluding the usage contract incorporating the terms and conditions.

Processor

blue media labs GmbH
Am Isenbrink 2a, 30926 Seelze, Germany
Contact person: Dr. Jan-Marco Bremer, Managing Director, info@blitzfin.com
No data protection officer has been appointed (no statutory obligation).
Accession: by concluding the usage contract.

Annex II – Description of the processing

Categories of data subjects

• Employees and other users of the controller
• Persons invited by the controller into project rooms, e.g. building owners, planners, project managers and their employees
• Contractors (executing companies, planners, suppliers) and their employees, including sole traders
• Other persons named in uploaded documents or documents received by email (e.g. contact persons on invoices)

Categories of personal data

• Contact and role data of project participants: name, business email address, telephone number where provided, role and permissions in the project room
• Log data: who performed which action and when (e.g. review and approval of invoices), for approvals including the IP address
• Content of documents (e.g. invoices, quotes, contracts, change orders) with the details they contain, in particular names, addresses, contact details, bank details, tax numbers or VAT identification numbers, and signatures
• Emails to the invoice inbox addresses of the project rooms: sender, recipient, subject, content and attachments
• Cost, order and payment data, insofar as it relates to natural persons (e.g. sole traders)

Sensitive data

Processing of sensitive data is not intended. The controller does not upload documents whose purpose is the processing of sensitive data. Should documents contain such data in individual cases, the same measures under Annex III apply; in particular, they are visible only to the authorized members of the respective project room.

Nature of the processing

Storing, hosting, displaying and structuring data; receiving and sending emails; automated reading of document content, including with the help of an AI language model; calculations and analyses; export; deletion.

Purposes of the processing

• Provision and operation of the BlitzFin platform for the controller's construction cost controlling (project rooms, cost tracking under DIN 276, reports)
• Receipt, capture, review and approval of invoices and other documents, including AI-assisted reading of documents
• Email notifications to project participants
• Technical support at the request of the controller or its users
• Testing of features only on documented instruction in the individual case (Part B.5)

Duration of the processing

For the term of the usage contract, including read access after project completion, and until deletion under Part B.7.

Processing by sub-processors

Subject matter, nature and location of processing by sub-processors are set out in Annex IV. The duration corresponds to the duration of processing by the processor.

Annex III – Technical and organisational measures

Physical security

• The platform is operated exclusively in Google Cloud data centers (Frankfurt am Main region). Google Cloud is certified, among others, to ISO/IEC 27001, 27017 and 27018 and holds SOC 2 reports; access control and physical protection lie with the data center operator.
• The processor does not operate its own servers.

Encryption

• All connections are TLS-encrypted: between browser and platform, between the platform's components, and to the database.
• Stored data (database and documents) is encrypted by default by Google Cloud (AES-256).
• Devices with access to platform administration use full-disk encryption and an automatic screen lock.

Identification and authorization

• Login is password-free via personalized, time-limited login links sent to the stored email address.
• Existing sessions can be invalidated centrally for all users.
• Role-based permissions: users see only project rooms they have been invited to; within a project room, roles and visibility levels control who sees which contractors and documents and who may administer, approve or export.
• Access to the cloud infrastructure is limited to named individuals and protected by two-factor authentication. Services run under dedicated service accounts with only the permissions they need.

Access by the processor

• Only persons bound to confidentiality have access to customer data, and only to the extent required for operations and support.
• Viewing an account by support (“view mode”) takes place only to handle requests and is logged as such.

Separation

• Tenants are logically separated by organization and project room.
• Test and production environments are separated; the test environment has no write access to production documents.

Logging

• Business-relevant actions (e.g. uploading, reviewing, approving invoices) are logged tamper-evidently with person and time and are visible to the members of the project room.
• Technical application logs are kept in Google Cloud Logging.

Availability and recovery

• Operation on managed, automatically scaling services (Google Cloud Run, Cloud SQL, Cloud Storage).
• Daily automatic database backups.
• Protection against overload attacks by the upstream Cloudflare network.

Data minimization and AI

• Payment method data is not stored (handled by Stripe).
• Only the original document being read is sent to the AI language model. Processing in the EU region only; no training with customer data; caching of inputs disabled.

Deletion and data portability

• Export function for the data of a project room.
• Deletion of project rooms and documents by authorized users; deletion periods under section 6 of the terms and conditions.

Review and sub-processors

• The measures are reviewed at least annually and upon material changes to the platform.
• Sub-processors are selected based on their security credentials (e.g. ISO/IEC 27001 certification) and contractually bound under Art. 28 GDPR.

Assistance to the controller (Clauses 8 and 9)

• Data subject rights: the controller can view, correct, export and delete data in the platform itself. Beyond that, the processor assists by email.
• In the event of a breach, the processor additionally reports, as far as known, the affected project rooms and the time period, in addition to the information under Clause 9.2.

Annex IV – List of sub-processors

Agreed list within the meaning of Clause 7.7(a) (general authorisation). As of: October 2, 2026. The current version is also published at blitzfin.com/subprocessors/.