Data processing and sub-processors

Draft — not yet reviewed by counsel. This page states how Forumulate processes customer data as the facts stand in the product and its operations. The contractual Data Processing Agreement is a legal document; until it is published, this page is a description, not an offer of terms.

Roles

For content and accounts in your organization, you are the controller and Forumulate is your processor. We process personal data only to provide the service you configured, on your documented instructions — the settings you choose in the product are those instructions.

For our own customer relationship (your billing contact, your account administrators' sign-in), Forumulate is the controller.

What we process

• Accounts: name, email, sign-in identifiers from your identity provider, session records.

• Content: what your members and readers write — pages, posts, replies, form submissions, uploads.

• Technical data: request logs and security events, kept for a limited period for operating and protecting the service.

Measurement on your public pages is first-party and consent-gated; nothing is sent to third parties unless you connect a vendor yourself (an analytics tag, a chat widget, a referral program), in which case that vendor is yours, not our sub-processor.

Sub-processors

Bring-your-own-key services (AI, embeddings, translation, outbound mail) run on your accounts with those providers and are not our sub-processors.

Ours — hosting, DNS and the network in front of the site, object storage for uploads and backups, transactional email, payments, crash reporting, and the identity layer every staff sign-in goes through — are named in our privacy policy; see also Privacy and GDPR and Atlas, and who processes your data. A procurement tool can poll a sub-processor table as data (Trust center).

Your rights as controller

• Data-subject requests: fulfilled in the product and through the privacy executor contract, so your privacy tooling can automate them.

• Export and deletion: see Settings, exports and deletion.

• Security: tenant isolation is enforced in the database, not only in application code; tokens and secrets are stored hashed or encrypted.

• Breach notification: without undue delay after we become aware of a breach affecting your data.

Open items before publication

• The signed DPA template (standard contractual clauses for transfers out of the EEA/UK) — a legal decision, not a product one.

• Exact retention periods for technical logs, to be stated per log class.

• The notice period and channel for sub-processor changes, and the objection procedure.