Data processing agreement
Effective
This agreement is part of the Terms of service between Sentinela ("processor") and the customer ("controller") and applies when Sentinela processes personal data on the customer's behalf.
Scope and duties
- Subject and duration. We process personal data contained in the customer's websites and in the access details the customer provides, to deliver scans, audits, remediation and Care Plans. Processing lasts as long as the services, plus the retention periods below.
- Data and people concerned. Screenshots, page code and structure of the customer's website, which may show personal data of the customer's staff or website users; site login or admin details provided by the customer; Care requests.
- Our duties. We process the data only on the customer's documented instructions (these terms and the customer's use of the service). We keep it confidential, limit access to staff who need it, and help the customer answer data-subject requests and meet its security obligations.
Security
Encryption in transit; encryption of stored secrets and site credentials; separation of customer data in the database; masking of password and card fields in screenshots; two-factor authentication for staff; logged access to remediation credentials; encrypted backups.
Sub-processors
The customer authorizes the sub-processors listed below. We will announce new ones on this page at least 14 days in advance; the customer may object by email to hello@sentinela.systems, and if we cannot accommodate the objection the customer may end the affected service.
| Provider | Purpose | Location |
|---|---|---|
| Cloudflare | Network security, DNS, file and backup storage (R2) | Global network; R2 storage in Cloudflare's default jurisdiction |
| DigitalOcean | Application and database server | Singapore |
| Anthropic | AI-assisted review of scan results | United States |
| Resend | Email delivery | United States |
| Sentry | Error monitoring (no personal data sent on purpose) | European Union (Germany) |
| PayPal (PayPal Pte. Ltd.) | Payments | Singapore |
Google, Meta and Cal.com process data for Sentinela's own marketing, with Sentinela as the controller, and are listed in the Privacy policy, not here.
Breaches, deletion and audits
- Personal data breaches. We notify the customer without undue delay, and within 72 hours where possible, after becoming aware of a breach affecting its data.
- Deletion. Scan data is deleted at the end of the plan's retention period (90, 180 or 365 days); audit and remediation evidence after 3 years; remediation access details when the work ends or is canceled; all customer data 30 days after the organization is deleted, except backups, which expire on their own schedule.
- Audits. On written request, once a year, we answer reasonable questions about our security measures.
Transfers
Where data leaves the EU/EEA or the UK, transfers rely on the standard contractual clauses or an equivalent safeguard.