Data Processing Addendum (DPA)

Effective Date: August 28, 2025
Version: V1.0

This Data Processing Addendum (“DPA”) forms part of the service agreement between Kyrion Media (“Processor”) and its Clients/Agencies (“Controller”) who use our content distribution, publishing, and related services (the “Services”).

1. Definitions

- Controller – The Client who determines the purpose and means of personal data processing.
- Processor – Kyrion Media, who processes personal data on behalf of the Client.
- Personal Data, Processing, Data Subject – As defined under GDPR and applicable privacy laws.

2. Scope & Purpose

Kyrion Media processes personal data only as necessary to provide Services, including but not limited to:

- Content publication and syndication
- Sponsored posts and advertising campaigns
- Account management and billing
- Analytics and reporting
- Compliance with legal obligations

3. Controller Obligations

Clients confirm that:

- They have obtained all required rights, consents, and lawful basis to share personal data with Kyrion Media.
- Shared personal data is accurate, relevant, and lawful.

4. Processor Obligations (Kyrion Media)

We agree to:

- Process data only on documented Client instructions.
- Implement appropriate technical and organizational safeguards.
- Restrict access to authorized personnel only.
- Assist Clients with data subject rights (access, correction, deletion, portability).

5. Sub-Processors

We may engage sub-processors (e.g., hosting, analytics, cloud providers). All sub-processors are contractually bound by equivalent data protection obligations. A list of sub-processors is available upon request.

6. International Data Transfers

Personal data may be transferred outside the Client’s country of origin (including the US, EU, UK, India, and Asia). Such transfers will be safeguarded using:

- Standard Contractual Clauses (SCCs)
- Adequacy decisions by relevant regulators
- Data Privacy Framework participation

7. Data Breach Notification

In the event of a confirmed data breach, Kyrion Media will:

- Notify the Client without undue delay.
- Provide scope, impact, and remediation details.
- Cooperate with any legal or regulatory obligations.

8. Audit Rights

Clients may request audits of Kyrion Media’s processing activities with reasonable prior notice (not more than once annually, unless legally required).