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Data Processing Agreement (DPA)

The Data Processing Agreement (DPA) governs, pursuant to Art. 28 GDPR, the processing of personal data by 9brains GmbH within the 9brains platform. It takes effect automatically upon account registration, without forms or waiting times.

Download DPA as PDF

The PDF (34 pages, as of May 2026) covers:

  • Standard contractual clauses (clauses 1 to 10): obligations of both parties, right to issue instructions, purpose limitation, security of processing, use of AI systems, sub-processors, international data transfers, data breaches, audit rights and liability
  • Annex I: List of contracting parties
  • Annex II: Description of the processing (data categories, data subjects, purposes, duration)
  • Annex III: Technical and organizational measures (TOMs)
  • Annex IV: List of all sub-processors with address, purpose, server location and DPA status
  • Appendix to Annex IV: Detailed information on data processing by each AI provider (contractual basis, assurances regarding data use, storage location, third-country transfer)

Do you support us with a data protection impact assessment?

Section titled “Do you support us with a data protection impact assessment?”

Yes. The annexes of the DPA provide the technical basis for your data protection impact assessment under Art. 35 GDPR: the description of the processing, the technical and organisational measures and the list of sub-processors with processing location and third-country relevance. You carry out the assessment yourselves as the controller; we help with any questions from your data protection officer.

For questions about the DPA or data protection:

Further information: Data protection & data sovereignty