Data Processing Addendum

This Data Processing Addendum ("DPA") forms part of the Terms of Service between Matchfyre ("Matchfyre", "Processor") and the customer ("Customer", "Controller") and applies where Matchfyre processes personal data on the Customer's behalf, in particular landing-page visitor and conversion data captured by the Matchfyre snippet.

1. Roles

The Customer is the controller of personal data captured on the Customer's landing pages. Matchfyre is the processor, processing such data only on the Customer's documented instructions (which include the configuration the Customer sets in the Service).

For Customer account and billing data, Matchfyre acts as an independent controller under the Privacy Policy.

2. Subject-matter, nature, and purpose

• Subject-matter: provision of the Matchfyre Service (personalization, conversion capture, CPL/ROI reporting).
• Nature/purpose: matching ad-click intent, recording conversion events (form leads, call clicks), and computing reporting metrics.
• Duration: for the term of the Service plus any retention period described in the Privacy Policy.

3. Categories of data and data subjects

• Data subjects: visitors to the Customer's landing pages.
• Categories: ad-click parameters (e.g. gclid, msclkid, adgroupid, targetid, location criteria IDs), conversion events and timestamps, a first-party attribution cookie identifier, technical data (IP, user agent) processed for security/operation. The Customer must not configure the Service to send special-category data.

4. Matchfyre's obligations

• Process personal data only on the Customer's documented instructions.
• Ensure persons authorized to process data are bound by confidentiality.
• Implement appropriate technical and organizational measures (see §7).
• Assist the Customer with data-subject requests and with security/breach and DPIA obligations, taking into account the nature of processing.
• Notify the Customer without undue delay after becoming aware of a personal-data breach.
• At the Customer's choice, delete or return personal data at the end of the Service, save where retention is legally required.

5. Sub-processors

The Customer authorizes Matchfyre to engage the sub-processors below. Matchfyre imposes data-protection obligations on each and remains responsible for their performance.

Sub-processor	Purpose	Region
Cloudflare	Hosting, CDN, edge compute, security	US / EU
Neon	Managed PostgreSQL database	US / EU
Clerk	Authentication and identity	US
Google	Google Ads API	US
Anthropic (Claude)	Generating the personalization plan (no training on your data)	US

Matchfyre will give notice of intended changes to sub-processors, allowing the Customer to object on reasonable data-protection grounds.

Note re: AI / Google Ads data. Account-structure data sent to Anthropic (Claude) to generate the personalization plan is processed under contractual terms that prohibit use of that data for training generalized models, consistent with the Google API Services Limited Use policy.

6. International transfers

Where personal data is transferred outside the EEA/UK, the parties rely on appropriate safeguards such as the EU Standard Contractual Clauses and any required supplementary measures.

7. Security measures

• Encryption of ad-platform OAuth tokens at rest (AES-GCM); no plaintext storage of secrets.
• Tenant isolation by workspace_id on every query.
• Transport encryption (TLS) in transit.
• Least-privilege access controls and audit logging.
• The snippet is designed to be non-blocking and to minimize data collected to what is necessary.

8. Audit

Matchfyre will make available information reasonably necessary to demonstrate compliance with this DPA and allow for audits subject to reasonable confidentiality and frequency limits.

9. Liability and term

This DPA is governed by the Terms of Service and continues for as long as Matchfyre processes personal data on the Customer's behalf.

10. Contact

Data protection: [email protected]. Matchfyre, 15 rue Jean Moulin, 69300 Caluire-et-Cuire, France.