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Draft — under legal review. This text has not been approved and is not yet in force. It will change before launch.

Data processing agreement

Draft of 3 October 2026.

This agreement ("DPA") forms part of the terms of service between the customer (the "controller") and [legal entity name] (the "processor") and applies whenever UsherStats processes personal data on the customer's behalf. It sets out the terms required by Article 28 of the General Data Protection Regulation (GDPR) and the UK GDPR.

1. Subject matter and duration

The processor provides web analytics and bot protection for the controller's websites, for as long as the controller's account exists and until the data is deleted under section 9.

2. Nature and purpose

Collecting, classifying, storing, aggregating and displaying data about visits and requests to the controller's websites, and deciding whether requests are automated, solely to provide the service to the controller.

3. Types of data and data subjects

Data subjects: visitors to the controller's websites. Data: pages visited, referring host, campaign tags, browser language, time zone and window size, country, network operator, device class, interaction measures, named events, and, while a request is handled and not stored, IP address and browser identification string. No special categories of data are processed. Details are in the privacy policy.

4. Processor obligations (Article 28(3))

5. Subprocessors

The controller gives general authorisation for the subprocessors listed on our subprocessors page. The processor will give at least 30 days' notice of a new subprocessor by email and on that page; the controller may object on reasonable grounds and, if no solution is found, terminate the affected service. The processor imposes the same data protection obligations on each subprocessor and remains liable for it.

6. International transfers

Where personal data is transferred outside the European Economic Area, the UK or Switzerland to a country without an adequacy decision, the parties rely on the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914), Module Two (controller to processor) and, for onward transfers, Module Three, with the UK International Data Transfer Addendum where the UK GDPR applies. [SCC annex details: docking clause, governing law, competent supervisory authority]

7. Controller obligations

The controller is responsible for the lawfulness of the collection, including any notices and consents its jurisdiction requires, and for its instructions complying with data protection law.

8. Data minimisation by design

The service sets no cookies on visitors for analytics (bot protection sets one, us_pass, only on a visitor who has completed a challenge), stores no IP addresses or browser identification strings with analytics, and does not record browsers that send Global Privacy Control.

9. Retention and deletion

Data is kept until the controller deletes it, sets a retention period, or closes the account, after which it is deleted [deletion period]. The controller can export its data at any time.

10. Contact

privacy@usherstats.com