Data Processing Agreement (DPA)

Under Article 28 GDPR · Social Media Director — Virtual Director Kft.

These terms (the Data Processing Agreement) are concluded between the User (Tenant) as data controller and Virtual Director Kft. (Social Media Director) as data processor, with respect to the personal data that the User processes through the system about its own audience, about individuals appearing in uploaded images, and about persons associated with its connected social accounts. The DPA is an inseparable part of the Terms of Service.

1. Subject and duration of the processing

The subject of the processing is the processing of data entered and managed by the User for the purpose of providing the Social Media Director service, for the duration of the User’s subscription.

2. Nature and purpose of the processing, data subjects and data

3. Obligations of the data processor

4. Sub-processors

The User grants a general authorisation to use the sub-processors listed below. When adding or replacing a sub-processor, the Service Provider informs the User in advance, and the User may object on reasonable grounds.

Sub-processorActivityLocation
RackForest Zrt.Server hostingEU / Hungary
OpenAI, L.L.C. / OpenAI Ireland Ltd.AI text and image generationEU / USA (SCC)
Meta Platforms Ireland Ltd.Publishing and analytics (Graph API)EU / USA (DPF)
LinkedIn Ireland Unlimited Company (Microsoft)Publishing and analytics (Marketing / Community Management API)EU / USA (DPF)
Cloudflare, Inc.CDN, R2 image storageUSA (DPF)
Microsoft Ireland Operations Ltd.Transactional e-mailEU
Google LLCEncrypted backupUSA (DPF)

The full, up-to-date list is available in the Privacy Policy.

5. Liability

The parties are liable in accordance with the GDPR and the Terms of Service concluded between them. The User warrants that it has an appropriate legal basis for the processing of the data it enters and manages — including the data of persons appearing in uploaded images.