Data Processing Agreement — Article 28 GDPR
Version 30/07/2026. This Agreement forms an integral part of the PreventivOk Terms of Use when a professional user entrusts Augello Antonio with processing personal data on the user’s behalf.
1. Parties, roles and subject matter
The professional user is the controller of personal data concerning clients, collaborators and contacts entered in the service. Augello Antonio, a natural person and owner of PreventivOk, acts as processor only for that data and under the user’s documented instructions. Processing includes hosting, organisation, consultation, modification, document generation, transmission on instruction, protection and deletion required to provide the service. It lasts from entry until deletion or return on termination, subject to legal duties.
2. Data subjects, data and purposes
Data subjects may include the user’s clients, prospective clients, contacts, suppliers and collaborators. Data may include identifiers, contact, ordinary professional and tax data, and information in quotations, costs, payments, notes and documents. Special-category data, health data, passwords, authentication codes and complete card data must not be entered. Purposes are delivery, security, support and continuity of requested functions.
3. Instructions, confidentiality and security
Augello Antonio processes data only under the Terms, this Agreement, settings and operations confirmed by the user, except for legal requirements notified where permitted. Authorised persons are bound by confidentiality. Measures include HTTPS, authentication, authorisation, logical account separation, restricted access, technical-log recording and deletion, and component maintenance. If an instruction infringes data-protection law, Augello Antonio informs the user and may suspend it.
4. Subprocessors and transfers
The user generally authorises Hetzner for hosting and storage, Cloudflare for network and security, Amazon Web Services/SES for email, Sentry for crash monitoring, and OpenAI only when Poki is activated and used. Equivalent obligations apply and Augello Antonio remains responsible within Article 28 GDPR. Material changes are notified before taking effect and the user may object on documented grounds; if no reasonable alternative exists, the affected function or service may be terminated. Extra-EEA transfers and safeguards are described in the Privacy Policy.
5. Assistance, breaches, return and audits
Augello Antonio assists the user where possible with data-subject requests and duties concerning security, breaches, impact assessments and consultations, and reports known personal-data breaches without undue delay. On termination, at the user’s choice, data and copies are returned or deleted, subject to legal duties and the technical periods in the Privacy Policy. Information necessary to demonstrate compliance is made available and reasonable audits agreed in advance are allowed while protecting security and confidentiality. The user ensures lawfulness, transparency, accuracy, minimisation and notices to data subjects.
6. Priority, contact and applicable law
This Agreement prevails for processing on the user’s behalf; the Terms govern all other matters. The GDPR and Italian law apply, subject to mandatory jurisdiction. Contact: Augello Antonio, Via Scaramuzzi 6, 71013 San Giovanni Rotondo (FG), Italy — [email protected].