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FreightParse

FreightParse Licence Terms (version 2.1, 14 October 2026)

Accepting these terms online

Terms version 2026-10-14

  • Who accepts. These terms are accepted online, on freightparse.com/trial/, by the person who signs up there, on behalf of the company that person names. That company is the Customer in each of the documents below.
  • Authority. By ticking the box on that page, the person confirms that they are authorised to accept the Trial Terms, the Data Processing Agreement and the Licence Terms for that company.
  • Date of acceptance. The date and time (UTC) of the sign-up. The confirmation page shows it.
  • Version. This is version 2026-10-14 of the three pages: freightparse.com/legal/trial-terms.html (the Trial Terms, with the Cloud Reading Addendum), freightparse.com/legal/dpa.html (the Data Processing Agreement) and freightparse.com/legal/licence-terms.html (the Licence Terms). The documents keep their own version lines: Cloud Reading Addendum version 1.3 of 14 October 2026, Data Processing Agreement version 1.1 of 9 October 2026, and Licence Terms version 2.1 of 14 October 2026.
  • The record. We record each acceptance: the details entered, the date and time, the internet address and browser it came from, this version, a fingerprint (SHA-256) of the three pages exactly as they were served, and the identifier of the access key. We never record the access key itself.
  • In place of signatures. For a trial accepted this way, that record takes the place of the party details and the signatures at the end of the Cloud Reading Addendum and the Data Processing Agreement.

Version 2.1, 14 October 2026. These terms are general terms and conditions (algemene voorwaarden) within the meaning of article 6:231 of the Dutch Civil Code.

1. Definitions

In these Terms:

1.1 Supplier, we or us: Danil Sysenko, trading as Sysenko and FreightParse, sole proprietorship (eenmanszaak) registered with the Netherlands Chamber of Commerce (KVK) under number 42184908, Mathenesserweg 122B01, Rotterdam, the Netherlands.

1.2 Customer or you: the business named in the Offer, the order confirmation or the invoice.

1.3 Agreement: the agreement between us and the Customer for a Licence or a Test Licence. It consists of the accepted Offer (or, for a Test Licence, the e-mail that delivers the test version), these Terms and, where clause 10 applies, the Data Processing Annex. The Offer prevails over these Terms only where it expressly says that it departs from a numbered clause of these Terms. In all other cases these Terms prevail.

1.4 Offer: a written offer from us that states that these Terms apply and includes them or has them attached.

1.5 Software: the FreightParse Windows program, its updates, its documentation and its licence check.

1.6 Licence: the right to use the Software granted under clause 4. Test Licence: the free right granted under clause 5.

1.7 Licence File: the file we issue that activates the Software on a PC or for the Customer's whole company.

1.8 PC: one Windows computer, physical or virtual, identified by the code the Software shows for it.

1.9 Licence Year: a period of 12 months starting on the day we send the Licence File, unless the Offer states another start date.

1.10 Output: the goods lines, spreadsheets, import files and reports that the Software produces.

1.11 Customer Documents: invoices, packing lists, transport documents and any other documents that the Customer processes with the Software or chooses to send to us.

1.12 In writing includes e-mail. Working day means Monday to Friday, except public holidays in the Netherlands.

2. Scope and application

2.1 These Terms apply to every Offer, every Agreement, every Licence and Test Licence, and every related service, including the reading of documents that the Customer sends to us.

2.2 We contract only with businesses that act in the course of their trade or profession. By requesting an Offer, accepting an Offer or using a Test Licence, the Customer confirms that it does so. We do not contract with consumers.

2.3 We expressly reject the applicability of any general terms, purchase terms or other conditions of the Customer, whether the Customer refers to them in a request, an order, a purchase order, an acceptance or anywhere else. They do not apply to any Agreement, even if they state that they prevail, unless we accept them in writing for a specific Agreement.

2.4 A departure from these Terms binds us only if we agree to it in writing, and only for the Agreement for which it was agreed.

2.5 If we do not enforce a provision of these Terms on one occasion, we keep the right to enforce it later.

3. Formation of the Agreement

3.1 Offers. An Offer can be accepted until the date stated in it, or within 30 days of its date if it states none. We are not bound by an Offer that contains an obvious mistake or slip.

3.2 These Terms come with every Offer. We send these Terms with every Offer, included in the Offer document or attached to the same e-mail, in a form that the Customer can store and print, so that the Customer can read them before accepting.

3.3 Acceptance. The Agreement is formed when the Customer accepts the Offer in writing within its validity period, for example by replying "agreed" by e-mail, together with the number of PCs where the Offer asks for it. E-mail is an agreed means for making the Agreement and for providing these Terms.

3.4 Acceptance that departs from the Offer. If an acceptance departs from the Offer, even on a minor point, no Agreement is formed unless we confirm the changed terms in writing. If the Customer's acceptance, or any earlier request or order, refers to the Customer's own terms, clause 2.3 applies.

3.5 Confirmation. After acceptance we send an order confirmation by e-mail with these Terms attached. If the order confirmation is inaccurate, the Customer must tell us within 5 Working days of receiving it.

3.6 Delivery. We deliver the Licence File by e-mail, normally on the day the Customer sends the codes of its PCs. Delivery by e-mail is delivery of the Software and the Licence File.

4. Licence grant

4.1 Grant. Once the Agreement is formed, we grant the Customer a non-exclusive, non-transferable right, without the right to sublicense, to use the Software during the Licence Year:
(a) per PC: on the number of PCs stated in the Offer or the order confirmation; or
(b) company licence: on any number of PCs of the legal entity named in the Offer, at all its establishments. Group companies and other legal entities are covered only if the Offer names them.

4.2 Use for the Customer's clients. The Customer may use the Software and the Output in its own business, including to prepare customs declarations and other documents for its own clients. The Software may be used by the Customer's employees and by individuals who work for the Customer under its direction.

4.3 What is not allowed. The Customer may not:
(a) sell, rent, lend, sublicense or otherwise make the Software or a Licence File available to anyone else, including its clients;
(b) let third parties use the Software themselves, for example through remote access or a hosted service;
(c) use the Software on more PCs than it has paid for, or work around the licence check;
(d) remove or change licence notices in the Software or in its reports.

4.4 Servers and shared desktops. If the Software runs on a server or virtual desktop that more than one person can use at the same time, each person who can use it at the same time counts as one PC.

4.5 Replacement PC. On request we issue a Licence File for a PC that replaces a licensed PC. The Customer then stops using the Software on the old PC.

4.6 Extra PCs. An extra PC added during a Licence Year is charged at the extra-PC price in the Offer for a full Licence Year starting on the day we send its Licence File, unless the Offer states otherwise.

4.7 End of the Licence Year. The Licence ends at the end of the Licence Year unless the Customer renews it under clause 14.2. The Software may then stop working. The Customer keeps all Output it has made.

4.8 Third-party components. The Software contains third-party (including open-source) components. Their own licence terms apply to those components, and nothing in these Terms limits the rights those licences give.

5. Test Licence

5.1 Grant. We may grant a free Test Licence for the period we state when we deliver the test version. The Test Licence is formed when the Customer, having received these Terms with the test version, starts to use it. The test version stops working at the end of that period.

5.2 Purpose. A Test Licence is only for evaluating whether the Software suits the Customer. Clauses 4.2 to 4.4 apply to it.

5.3 As is. The test version is provided as it is, without any promise about what it does, and clause 8 does not apply. We may end a Test Licence at any time by e-mail.

5.4 Real declarations. If the Customer uses Output produced under a Test Licence in a real declaration, it does so at its own risk and only after the checks in clause 7.

5.5 No liability. As far as the applicable law allows, we are not liable for any loss arising from a Test Licence, from the test version or from its Output. This exclusion does not apply to loss caused by our intent or deliberate recklessness, nor to the cases listed in clause 9.6.

5.6 All other clauses of these Terms, including those on confidentiality, intellectual property, data protection, law and forum, apply to a Test Licence.

6. Fees, invoicing and payment

6.1 Prices. The fees are those stated in the Offer, in euro, excluding VAT. VAT is added where the law requires it. If the reverse-charge rules apply, the Customer accounts for the VAT and gives us its VAT ID.

6.2 Invoicing. We invoice the fee for each Licence Year in advance, on or after the day we send the Licence File. The Customer pays each invoice within 30 days of the invoice date.

6.3 Objections. The Customer raises any objection to an invoice in writing, with reasons, within 14 days of the invoice date, and pays the undisputed part on time.

6.4 Set-off. The Customer may not set off what it owes us against a claim it has against us, unless we accept that claim in writing or a court has awarded it.

6.5 Late payment. If the Customer does not pay on time, it is in default without any reminder being needed. From the day after the due date it owes the statutory commercial interest under article 6:119a of the Dutch Civil Code (BW) on the unpaid amount. It also owes the reasonable costs of collecting the debt out of court under article 6:96 BW, which are at least EUR 40.

6.6 Suspension. If an invoice is still unpaid 14 days after we send a written reminder, we may suspend support, updates and the issue of new Licence Files until the Customer has paid.

6.7 Prices for a new Licence Year. The fees for a Licence Year are fixed for that year. The fees for a following Licence Year are those stated in the renewal Offer under clause 14.2.

6.8 No refunds. Paid fees are not refunded, except under clauses 8.2, 8.3, 12.5, 13.7, 14.4 and 15.3.

7. The Customer's responsibilities and the declarant's duty

7.1 An aid, not a declarant. The Software proposes values read from the Customer Documents. It does not lodge declarations, does not decide any tariff classification, origin, preference or customs value, and does not give customs, tax or legal advice.

7.2 Check every value. Before the Customer lodges a declaration, or uses Output in any other way that has legal or financial effect, a competent person working for the Customer checks every value in the Output against the source documents and the applicable law, and corrects it where needed. This includes the commodity code, description, origin, weights, packages, value and currency, and in particular every item that the report shows as missing, uncertain or in conflict between documents.

7.3 The Customer stays responsible to customs. The Customer remains solely responsible, to the customs and tax authorities and to its own clients, for every declaration it lodges or that is lodged on its behalf, whether or not it used Output, and whether it acts in its own name or as a customs representative.

7.4 The Customer's own area. The Customer is responsible for its choice of the Software, for its right to process the Customer Documents, for its PCs, network, security and back-ups, for importing Output into its declaration software and checking that import, and for instructing its staff.

7.5 Claims by the Customer's clients and authorities. The Customer indemnifies us against claims by third parties, including its clients and any authority, that arise from a declaration lodged by or on behalf of the Customer, unless the loss was caused by our intent or deliberate recklessness. "Indemnifies" means that the Customer bears those claims and our reasonable costs of defending them.

7.6 Reporting wrong Output. The Customer tells us without undue delay of wrong Output that it finds, so that we can fix the cause. It sends the document concerned only if it chooses to, under clause 10.

8. Warranty

8.1 30-day fix or refund. For 30 days after we first send the Licence File for the Customer's first paid Licence Year, we warrant that the Software does substantially what the Offer describes when it is used on the Customer's own computer-made PDF documents of the kinds the Offer names. Scans and photos are outside this warranty: the Software reports them and leaves them unread.

8.2 How it works. If the Customer tells us in writing within those 30 days, with examples, that the Software does not do so, we will fix the problem or provide a workaround within a reasonable time. If we cannot do so within 30 days of the Customer's notice, either party may end the Licence by written notice, and we refund the fee paid for that Licence Year. The Customer then stops using the Software and deletes it.

8.3 Later in the Licence Year. If, after the first 30 days, a defect makes the Software substantially unusable for the purpose the Offer describes and we do not fix it or provide a workaround within 30 days of the Customer's written notice, the Customer may end the Licence by written notice. We then refund the part of the fee that relates to the rest of that Licence Year.

8.4 No other promises. Apart from clauses 8.1 to 8.3, the Software is provided as it is. We do not promise that it reads every document correctly or completely, that the Output is free of errors, or that the Software runs without interruption. The Output is a proposal that the Customer checks under clause 7.

8.5 What the warranty does not cover. Clauses 8.1 to 8.3 do not apply to problems caused by use contrary to these Terms or the documentation, by changes not made by us, or by the Customer's PCs, operating system, network or other software.

8.6 Sole remedy. Clauses 8.1 to 8.3 set out the Customer's only remedies for defects in the Software, subject to clause 9.6.

9. Limitation of liability

9.1 Why this clause exists. Our fees are set on the basis that the Customer checks every value before it lodges a declaration (clause 7), and that our liability is limited as set out in this clause 9.

9.2 Cap. Our total liability for all loss arising from or in connection with the Agreement, whether in contract, in tort or on any other ground, is limited to the higher of: (a) the fees the Customer paid under the Agreement in the 12 months before the event that caused the loss; and (b) the fee for the Licence Year in which that event occurred. Connected events count as one event, which occurs when the first of them occurs.

9.3 Excluded loss. We are not liable for indirect or consequential loss, including lost profit, lost revenue, lost savings, loss of goodwill, business interruption, and loss or corruption of data. Whether the loss is direct or indirect, we are also not liable for:
(a) customs duties, import VAT and other taxes, excise duties, levies, and anti-dumping or countervailing duties;
(b) fines, penalties, administrative sanctions, interest and surcharges imposed by any authority;
(c) the cost of correcting, amending or invalidating a declaration, including the cost of advisers and of post-clearance procedures;
(d) loss caused by goods being held, delayed or seized;
(e) claims by the Customer's clients or other third parties.

9.4 Notice and time limit. The Customer may claim compensation only if it notifies us in writing, with reasons, within 30 days after it discovered, or should reasonably have discovered, the loss. A claim lapses if the Customer has not started legal proceedings within 12 months of that notice.

9.5 Persons we engage. Persons we engage to perform the Agreement may rely on this clause 9 as if they were a party to it.

9.6 When these limits do not apply. The limitations and exclusions in clauses 5.5, 8.6 and 9 do not apply:
(a) to loss caused by our intent or deliberate recklessness;
(b) to liability for death or personal injury;
(c) to the extent that mandatory law does not allow liability to be excluded or limited;
(d) to the extent that the Belgian rules on unfair terms between businesses (Code of Economic Law, articles VI.91/1 and following) apply to the Agreement: to loss caused by gross negligence (zware fout) of us or of persons we engage. In that case clause 9.3 also does not apply to loss caused by our failure to perform an essential obligation of the Agreement, except in case of force majeure, but that liability remains limited under clause 9.2.

10. Data protection

10.1 The Software. The Software runs on the Customer's PCs and sends nothing to us. When the Customer uses the Software, we do not process personal data on the Customer's behalf.

10.2 Our own administration. We process the business contact details of the Customer's staff, and the PC codes the Customer sends us, as an independent controller, to issue Licence Files, invoice, give support and meet our legal obligations.

10.3 Documents the Customer sends us. If the Customer chooses to send us Customer Documents, for example a scanned page for us to read or a document that produced wrong Output, we process the personal data in them as the Customer's processor, and the Data Processing Annex (Annex 1) applies. "Processor" and "controller" have the meanings given in the General Data Protection Regulation (EU) 2016/679 (GDPR).

10.4 What the Customer sends. The Customer is responsible for having a lawful basis to send us the Customer Documents, and sends only what is needed for the purpose. The Customer does not send us identity documents, citizen service numbers (BSN) or special categories of personal data unless we have agreed to that in writing in advance.

11. Confidentiality

11.1 What is confidential. Each party keeps confidential the information it receives from the other party in connection with the Agreement that is marked as confidential or that it should reasonably understand to be confidential. This includes the Customer Documents, the names and shipments of the Customer's clients, and the non-public workings of the Software.

11.2 Use. Each party uses that information only to perform the Agreement, and shares it only with persons who need it for that purpose and who are bound by a duty of confidentiality.

11.3 Exceptions. Clause 11.1 does not apply to information that is or becomes public without a breach of this clause, that the receiving party already had or develops independently, or that it must disclose under the law or an order of a court or authority. In the last case it tells the other party first, where the law allows.

11.4 Duration. This clause applies during the Agreement and for 5 years after it ends, and for Customer Documents for as long as we hold them.

11.5 References. We name the Customer as a user of the Software, for example on our website, only with its prior written consent.

12. Intellectual property

12.1 Ours. All intellectual property rights in the Software, its rules and mappings, its documentation and any changes we make to them remain with us or our licensors. The Customer receives only the rights set out in clauses 4 and 5.

12.2 Yours. We claim no rights in the Customer Documents or in the Output. The Customer may use the Output freely in its business.

12.3 Copying and reverse engineering. The Customer may not copy, adapt, decompile or reverse engineer the Software, except where and to the extent that Chapter VI of the Dutch Copyright Act (Auteurswet, articles 45h to 45n) or other mandatory law allows it without our consent. Those rights include making a backup copy, the reproduction needed to load, display and correct errors in the Software, and, under the strict conditions set out in that Act, decompiling to make the Software work with an independently created program.

12.4 Ask us first. Before the Customer corrects an error or decompiles for interoperability, we ask it to report the error or request the interface information from us. We will provide a fix or the information within a reasonable time where we can.

12.5 Third-party claims. If a third party claims that use of the Software in line with these Terms infringes its rights, we will, at our choice and cost, obtain the right for the Customer to continue using it, change the Software so that it no longer infringes, or end the Licence and refund the fee for the rest of the Licence Year. The Customer tells us of such a claim promptly. Clause 9 applies.

13. Support and updates

13.1 What is included. During a paid Licence Year the Customer receives, at no extra charge, support by e-mail on Working days and the updates we release for the Software. We aim to answer a support e-mail within one Working day. That is an aim, not a guaranteed response time.

13.2 Setup. Where the Offer includes setup, we help to install the Software and to set up its import file for the Customer's declaration software from one of the Customer's own import files. We aim to complete this within 5 Working days of receiving that file.

13.3 What updates contain. We decide what an update contains. We aim to keep the Software working with the kinds of documents and the import format named in the Offer, and to follow changes in them, but we do not promise that every change will be supported, or supported in time.

13.4 Installing updates. If the Customer does not install an update that we provide to fix a problem it reported, clause 8 does not apply to that problem.

13.5 Outside support. Support does not cover the Customer's IT, its declaration software, or questions about customs law, classification or valuation.

13.6 Test Licence. During a Test Licence we help where we can, without any aim for response times.

13.7 If we stop. If we stop providing support and updates during a paid Licence Year, we tell the Customer in writing and refund the fee for the rest of that Licence Year.

14. Term, renewal and termination

14.1 Term. An Agreement for a Licence runs for the Licence Year stated in the Offer. A Test Licence runs for the period stated when we deliver the test version.

14.2 No automatic renewal. A Licence Year does not renew by itself. Before it ends we send the Customer an Offer for the next Licence Year. If the Customer accepts that Offer in writing, the next Licence Year starts on the day after the current one ends, under the version of these Terms that the renewal Offer states.

14.3 Ending for breach. Either party may end the Agreement by written notice with immediate effect if the other party seriously breaches it and does not remedy the breach within 14 days of a written notice that describes it. Either party may also end the Agreement by written notice, to the extent the law allows, if the other party is declared bankrupt, is granted a suspension of payments or stops its business.

14.4 Refund if we are in breach. If the Customer ends the Agreement under clause 14.3 because of our breach, we refund the fee for the rest of the Licence Year. If we end it because of the Customer's breach, no fee is refunded and all unpaid amounts become due at once.

14.5 What happens at the end. When a Licence or Test Licence ends, the Customer stops using the Software and deletes it and its Licence Files. Performance already given is not undone, except as stated in clauses 8 and 14.4. The Customer keeps its Output.

14.6 Clauses that survive. Clauses 6, 7.3, 7.5, 9, 10, 11, 12, 16 and 17 and Annex 1 continue to apply after the Agreement ends, to the extent needed.

14A. Monthly plan for cloud reading

14A.1 What it is. The monthly plan is cloud reading paid per document read. It starts on the day the Customer accepts it in writing, which may be a reply to our e-mail, and runs per calendar month. It continues from month to month until the Customer or we end it by e-mail; it then ends at the end of the month in which that e-mail was sent.

14A.2 Price. The price is EUR 0.35 for each document read, with at least EUR 49 a month, which includes the first 140 documents, excluding VAT. A document is one PDF of up to 5 pages. We may change the price by e-mail at least 30 days before the change applies; the Customer may end the plan before then under clause 14A.1.

14A.3 Invoicing. We invoice each month after it ends, for the documents read in it. The Customer pays within 14 days of the invoice date.

14A.4 Cloud reading terms. The Cloud Reading Addendum and the Data Processing Agreement apply to the monthly plan as they apply to the test.

14A.5 Licence Year clauses. Clauses 4.6, 6.2, 6.7, 8.1, 14.1 and 14.2, which are about the Licence Year, do not apply to the monthly plan. Where another clause refers to the fee for a Licence Year, for the monthly plan it means the fees paid in the 12 months before the event.

15. Force majeure

15.1 What it is. Neither party is liable for failing to perform an obligation, other than an obligation to pay, to the extent that the failure is caused by circumstances beyond its reasonable control that it could not reasonably have foreseen or avoided (force majeure). Examples are failures of telecommunication or e-mail services, power cuts, cyberattacks that we could not reasonably have prevented, changes to Windows made by its maker, measures by public authorities, epidemics, war and natural disasters, and, for us, serious illness or incapacity of Danil Sysenko.

15.2 What the affected party does. The affected party tells the other party promptly, limits the consequences where it can, and resumes performance as soon as possible.

15.3 If it lasts. If force majeure lasts more than 60 days, either party may end the Agreement by written notice. We then refund the fee for the rest of the Licence Year. Neither party owes any other compensation for the force majeure.

16. General provisions

16.1 Severability. If a provision of these Terms is void or is annulled, the other provisions remain in force. The parties then agree a valid provision that comes as close as the law allows to the purpose of the provision that failed.

16.2 Language. These Terms and the Agreement are in English. If they are translated, the English version prevails.

16.3 Changes to these Terms. We may publish new versions of these Terms. A new version applies only to Offers we make after it is published and to Licence Years that start under a renewal Offer that states it. During a running Licence Year, the version that applied at its start remains in force.

16.4 Entire agreement. The Agreement contains everything the parties have agreed about its subject and replaces earlier proposals and statements about it, to the extent that they are not repeated in the Offer or these Terms.

16.5 Transfer. The Customer may transfer its rights and obligations under the Agreement only with our prior written consent. We may transfer the Agreement, with all rights and obligations, to a company that continues our business, such as a private limited company (BV) that we set up. The Customer consents to that transfer in advance, and we tell it in writing when it happens.

16.6 Notices. Notices under the Agreement are sent by e-mail to the addresses stated in the Offer, or to another address that a party gives in writing.

17. Applicable law and forum

17.1 Dutch law. The laws of the Netherlands govern the Agreement and all non-contractual obligations arising from or in connection with it. The United Nations Convention on Contracts for the International Sale of Goods (Vienna, 1980) does not apply.

17.2 Talk first. Before starting proceedings, a party gives the other party a written description of the dispute, and the parties try to settle it within 30 days. This does not prevent a party from seeking urgent interim measures, or us from claiming unpaid invoices.

17.3 Court. The court in Rotterdam, the Netherlands (Rechtbank Rotterdam), including its subdistrict section (kantonrechter) where that section is competent, has exclusive jurisdiction over all disputes arising from or in connection with the Agreement, including disputes about its formation and validity and about this clause 17.3. This is an exclusive choice of court agreement for the purposes of the Hague Convention of 30 June 2005 on Choice of Court Agreements.


End of the Terms. Annex 1 follows and forms part of the Terms.

Annex 1. Data Processing Annex (GDPR art. 28)

A1.1 When this Annex applies. This Annex applies when the Customer chooses to send us Customer Documents that contain personal data (clause 10.3). The Customer is the controller and we are its processor. Terms defined in the GDPR have the same meaning here.

A1.2 The processing.

  • Subject matter and purpose: reading the Customer Documents the Customer sends us, returning the values read to the Customer, and finding the cause of wrong Output.
  • Nature: receiving by e-mail, viewing, transcribing values, returning the result by e-mail, and deleting.
  • Duration: from receipt until deletion under A1.9.
  • Types of personal data: names, business addresses, e-mail addresses, telephone numbers, signatures, vehicle registration numbers, and identification numbers such as EORI and VAT numbers of persons named in trade and transport documents.
  • Data subjects: contact persons and staff of the Customer, its clients, suppliers and carriers, drivers, and sole traders named in those documents.

A1.3 Instructions. We process the personal data only on the Customer's documented instructions. Sending a document with a request to read it, or to investigate wrong Output, is such an instruction. This also applies to transfers to a country outside the European Economic Area (EEA), unless the law requires otherwise; in that case we tell the Customer before processing, unless the law forbids that. We tell the Customer immediately if, in our opinion, an instruction infringes the GDPR or other data protection law.

A1.4 Confidentiality. Only Danil Sysenko processes the personal data. Anyone we may later authorise to process it is bound by a duty of confidentiality.

A1.5 Security. We take appropriate technical and organisational measures under article 32 GDPR, suited to a one-person business, including at least:

  • the personal data are kept only in our business mailbox and on our own computer, which uses full-disk encryption, a password-protected screen lock and current security updates;
  • the mailbox is protected by a strong, unique password and two-factor authentication;
  • we do not pass Customer Documents to any online OCR, translation or AI service, or to any other third party, except under A1.6;
  • we delete the data on time under A1.9.

A1.6 Sub-processors. The Customer gives us general written authorisation to engage sub-processors. Our only sub-processor is the provider of our business e-mail service, which stores the e-mails by which Customer Documents reach us and results are returned. We name it on request. We tell the Customer at least 30 days before we add or replace a sub-processor, so that the Customer can object; if it does, it may stop sending us documents and ask us to delete those we hold. We bind each sub-processor by contract to data protection obligations that meet article 28 GDPR, and we remain liable to the Customer for its performance of them.

A1.7 Assistance. Taking into account the nature of the processing and the information available to us, we help the Customer to respond to requests from data subjects and to meet its obligations under articles 32 to 36 GDPR. We pass any request we receive from a data subject to the Customer and do not answer it ourselves unless the Customer instructs us to.

A1.8 Personal data breaches. We notify the Customer without undue delay, and where possible within 48 hours, after we become aware of a personal data breach that affects the Customer's personal data, with the information that article 33(3) GDPR requires as far as we have it.

A1.9 Deletion. We delete the Customer Documents and all copies within 30 days after we return the result, or earlier at the Customer's request, unless the Customer asks us in writing to keep them longer for a stated purpose, or the law requires us to keep them. When the processing ends, we delete or return all remaining personal data, at the Customer's choice. Copies in our e-mail provider's backups are removed on that provider's normal schedule.

A1.10 Information and audits. We make available to the Customer all information necessary to demonstrate compliance with article 28 GDPR, and we allow for and contribute to audits, including inspections, by the Customer or by an auditor it mandates who is bound by confidentiality. An audit is announced at least 14 days in advance, normally takes place no more than once a year unless there has been a breach or a supervisory authority requires it, and is at the Customer's cost.

A1.11 Transfers outside the EEA. We do not transfer the personal data outside the EEA, except to return the result to a Customer established outside the EEA, which the Customer instructs by sending the document. For a Customer in the United Kingdom, that return relies on the European Commission's adequacy decision for the United Kingdom. If no adequacy decision applies, the parties agree the standard contractual clauses adopted by the European Commission (module four, processor to controller) before we return the result.

A1.12 UK customers. Where the Customer is subject to the UK GDPR, references to the GDPR include the UK GDPR and the Data Protection Act 2018, as far as they apply.

A1.13 Liability. Clause 9 of the Terms applies to this Annex, without limiting the rights of data subjects or any liability that the GDPR does not allow to be limited.

A1.14 Precedence and duration. On the processing of personal data, this Annex prevails over the rest of the Terms. It applies for as long as we hold personal data for the Customer.