Legal documents

Data processing agreement

Last updated · 13 August 2026 · version 1.0

When you use Thor Ads to process your customers' personal data, you are the controller and we are the processor. This agreement, under Art. 28 GDPR, describes what we do with that data and with what safeguards.

1. Roles of the parties

The customer acts as data controller; Thor Ads acts as processor and processes data only on the basis of the controller's documented instructions, including the use of the product itself.

2. Subject matter, duration and nature

The processing concerns the provision of the service for the duration of the subscription: importing, normalizing, analyzing and generating content from the connected advertising and sales data.

3. Categories of data and data subjects

Campaign data and aggregated metrics; order data imported by the controller, which may include identifiers of end customers. We do not process special categories of data under Art. 9 GDPR.

4. Sub-processors

We use sub-processors for hosting, email delivery, payments and AI models. The up-to-date list is available on request; we give prior notice of any change, with the controller's right to object.

5. Security measures

Encryption in transit and at rest, structural isolation per workspace, role-based access control, operation logging, periodic backups and documented recovery procedures.

6. Data breaches

In the event of a breach we inform the controller without undue delay, with the information needed for the notifications required by Arts. 33 and 34 GDPR.

7. Assistance to the controller

We provide reasonable cooperation in responding to data subjects' requests and for impact assessments and prior consultations, taking into account the nature of the processing.

8. Return and deletion

Upon termination of the contract, data is returned in an exportable format or deleted within [period], except for statutory retention obligations.

9. Transfers outside the EU

Any transfers outside the European Economic Area take place on the basis of the European Commission's standard contractual clauses and the applicable supplementary measures.

For any question about your data, write to privacy@heythor.ai.

Draft to be validated with legal counsel before publication · fields in square brackets must be filled in