← Back to Campoff
Campoff

Campoff Data Processing Agreement

Effective 25 October 2026

This agreement is an integral part of the Business Terms. It is made between the Customer (controller) and SIA Campoff, reg. no. 40203782686, "Bajāri", Vīpe parish, Jēkabpils municipality, Latvia (processor). It meets the requirements of GDPR Article 28(3). The Customer agrees to it when the Organiser ticks the box in the business portal.

1. Subject matter and duration

  • Campoff processes personal data on the Customer's behalf to run the Customer's business camps in the business portal: to show the Customer the member list, hours and progress towards the shared goal.
  • This agreement applies while the Customer has at least one camp in Campoff, and ends when the camp data has been deleted under section 9.

2. Nature of processing and types of data

See Annex 1.

3. Documented instructions

  • Campoff processes data only on the Customer's documented instructions. The instructions are:
    • this agreement and the Business Terms;
    • the Customer's actions in the business portal (creating a camp, settings, archiving);
    • the Customer's written requests to kristaps@campoff.app.
  • If Campoff believes an instruction breaches data protection law, Campoff informs the Customer immediately.
  • If the law requires Campoff to process data differently, Campoff informs the Customer before processing, unless the law forbids this.

4. Confidentiality

Only people who need access to provide the service have access to the data, and they have committed to confidentiality or are under a statutory duty of confidentiality.

5. Security

Campoff implements the technical and organisational measures under GDPR Article 32 described in Annex 2. Campoff may improve them but may not lower the overall level of protection.

6. Sub-processors

  • The Customer gives general authorisation to use the sub-processors listed in Annex 3.
  • Campoff informs the Customer at least 14 days in advance, by email or in the portal, before adding or replacing a sub-processor.
  • The Customer may object on reasonable grounds during that time. If no agreement is reached, the Customer may end the Business Terms and get a refund for paid time not yet used.
  • Campoff has a contract with each sub-processor that imposes the same data protection obligations as this agreement. Campoff is responsible for its sub-processors.

7. Assisting the Customer

  • Data subject rights. Campoff helps the Customer answer data subject requests (access, correction, deletion and so on). If a request about camp data reaches Campoff, Campoff forwards it to the Customer without delay or, if the request concerns the member's own Campoff account, handles it itself as the controller.
  • Other obligations. Campoff, as far as possible, helps the Customer meet its obligations under GDPR Articles 32–36: security, breach notification, impact assessment, prior consultation.

8. Personal data breaches

  • If Campoff becomes aware of a breach affecting camp data, Campoff notifies the Customer without undue delay and no later than 48 hours.
  • The notice contains as much as is known at the time: what happened, which data and how many people are affected, the likely consequences, and what Campoff is doing about it.
  • Campoff adds to it as more becomes known.

9. Data after processing ends

  • When the Customer asks in writing, or when the Business Terms end, Campoff deletes the business camp data within 30 days. If the Customer chooses, Campoff first returns it in a machine-readable format (CSV or JSON).
  • The data is deleted from backups no later than 30 days after that.
  • Members' own Campoff accounts and their time remain, because Campoff is responsible for them as the controller.
  • Invoice details remain for as long as the law requires.

10. Information and audits

  • Campoff gives the Customer the information needed to show that this agreement is being followed.
  • The Customer may carry out an audit itself or through an independent auditor bound by confidentiality. Audits are announced at least 30 days in advance, no more than once a year unless there has been a breach. Audits take place during working hours, and each party bears its own costs.
  • Campoff may first answer written questions and provide documents. An on-site audit takes place only if that is not enough.

11. Transfers outside the EEA

Campoff transfers data outside the European Economic Area only on a basis under Chapter V GDPR: an adequacy decision (for example the EU–U.S. Data Privacy Framework for certified companies) or the European Commission's Standard Contractual Clauses.

12. Customer obligations

The Customer is responsible for having a lawful basis to process the camp data and for members being informed (GDPR Article 13), as set out in section 5 of the Business Terms.

13. Liability and precedence

  • Liability is governed by section 8 of the Business Terms and GDPR Article 82.
  • If this agreement conflicts with the Business Terms on data protection matters, this agreement prevails.

Annex 1. Description of processing

Data subjectsMembers of the Customer's business camps (for example employees, team members) and Organisers
Types of dataMember's Campoff name; join date; time off screen counted within the camp's dates and hours (totals per day, week, month and overall); contribution to the shared goal; number of members; Organiser's email
Not processed on the Customer's behalfMembers' emails, individual session details, fair play signals, data about other camps, leagues, friends and the wallet. Campoff is responsible for these itself as the controller, and the Customer does not see them
Special categories of dataNone
Processing operationsStorage, calculation, display in the business portal, deletion
PurposeTo let the Customer run a voluntary camp and see its results
FrequencyContinuous, while the camp runs and while the Customer can view it

Annex 2. Technical and organisational measures

  • Encryption. All connections are encrypted with HTTPS (TLS). Push notification content is encrypted.
  • Sign-in. No passwords. One-time 6-digit codes, valid for 10 minutes, with limited attempts and a limited number of code requests per email and IP address.
  • Access control. The Customer sees only the camps its Organiser created. The business portal and admin portal have separate sign-in keys. The admin portal is open only to pre-set email addresses. Admin actions are logged.
  • Data minimisation. The Customer is shown only names and totals, not emails or sessions.
  • Browser protection. The portals use a strict Content Security Policy, load no external resources and use no analytics. Portal pages are never cached.
  • Backups. Consistent database copies before changes, kept no longer than 30 days, accessible only to the Campoff administrator.
  • Change control. Changes are tested locally before deployment, and a backup is taken before every deployment.
  • Hosting. Render infrastructure with physical and network security under Render's security programme.

Annex 3. Sub-processors

Sub-processorWhat it doesWhere
Render Services, Inc.Server, database, technical logsFrankfurt, Germany (EU); company in the USA
Resend, Inc.Sending sign-in code emails to Organisers and membersUSA