Legal · DPA

Data Processing Agreement

Last updated: January 1, 2025

1. Overview

This Data Processing Agreement ("DPA") forms part of the Terms of Service between HiheMAX Inc. ("Processor") and the Customer ("Controller"). It governs the processing of personal data on behalf of the Customer.

2. Definitions

"Personal Data", "Data Subject", "Processing", "Processor", and "Controller" shall have the meanings ascribed to them in GDPR Article 4.

3. Nature of Processing

HiheMAX processes personal data solely to provide the Swifton platform as described in the Terms of Service. HiheMAX acts only on documented instructions from the Customer.

4. Security Measures

HiheMAX implements the technical and organizational measures described in our Security Policy, including encryption, access controls, and regular security assessments.

5. Sub-processors

A current list of sub-processors is available at swifton.io/legal/sub-processors. We provide 30 days notice before adding new sub-processors.

6. Data Transfer

Data transfers outside the EEA are governed by Standard Contractual Clauses (SCCs) as approved by the European Commission. Enterprise customers can request specific data residency regions.

7. Signing the DPA

Enterprise customers requiring a signed DPA should contact legal@swifton.io. All Pro and higher plans automatically have this DPA incorporated into their agreement.