Zippendo

Legal

Data Processing Agreement

Last updated 20 August 2026 · Effective 22 July 2026 · Datatilsynet standard contractual clauses (Article 28(3) GDPR) governing Zippendo's processing of customer platform data.

Standard Contractual Clauses — August 2026

Based on the Danish Data Protection Agency (Datatilsynet) standard data processing agreement for Article 28(3) GDPR.

between

Zippendo ApS

Æbeløgade 26, 1. 2

8000 Aarhus C

Denmark

CVR 46636058

(the data processor)

and

The Customer

(the data controller)

each a party; together the parties

Document Structure

This Agreement consists of:

  1. Main body (this page)
  2. Appendix A — Information about the processing
  3. Appendix B — Authorised sub-processors
  4. Appendix C.2 — Technical and organisational security measures (TOMs)

2. Preamble

  1. These Contractual Clauses (the Clauses) set out the rights and obligations of the data controller and the data processor when processing personal data on behalf of the data controller.
  2. The Clauses have been designed to ensure the parties' compliance with Article 28(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation).
  3. In the context of the provision of Zippendo (the Services), the data processor will process personal data on behalf of the data controller in accordance with the Clauses.
  4. The Clauses shall take priority over any similar provisions contained in other agreements between the parties.
  5. Relationship to main agreement. This Agreement supplements the Zippendo Terms of Service published at https://zippendo.com/legal/terms-of-service (the Main Agreement), which governs the Customer's use of the Services. In case of conflict regarding the processing of personal data, these Clauses prevail.
  6. Appendices are attached to the Clauses and form an integral part of the Clauses.
  7. Privacy contact. Questions regarding this Agreement may be directed to [email protected].

3. The rights and obligations of the data controller

  1. The data controller is responsible for ensuring that the processing of personal data takes place in compliance with the GDPR (see Article 24 GDPR), the applicable EU or EEA Member State data protection provisions, and the Clauses.
  2. The data controller has the right and obligation to make decisions about the purposes and means of the processing of personal data.
  3. The data controller shall be responsible, among other things, for ensuring that the processing of personal data which the data processor is instructed to perform has a legal basis.
  4. The data controller shall ensure that data subjects whose personal data is processed through the Services receive appropriate information, including that Zippendo acts as data processor for consignment and order data and that carriers and customer-configured destinations receive data on the controller's instruction.
  5. The data controller is responsible for the lawfulness of data forwarded to customer-connected destinations (including webhooks, marketing platforms, and automation tools operated under the controller's own vendor accounts or API credentials, such as Customer.io, Klaviyo, SendGrid, Make, and similar third-party services). Those parties are selected and utilized at the controller's sole discretion and are not Zippendo sub-processors.
  6. Where the Customer connects external AI agents to the Services, such access is performed under the Customer's credentials and instruction. The Customer remains responsible for the lawfulness of that access and for any processing by third-party AI tools.

4. The data processor acts according to instructions

  1. The data processor shall process personal data only on documented instructions from the data controller, unless required to do so by Union or Member State law to which the processor is subject. Such instructions are specified in Appendix A and the main body of this Agreement. Subsequent instructions can also be given by the data controller throughout the duration of the processing of personal data, but such instructions shall always be documented and kept in writing, including electronically, in connection with the Clauses.
  2. The data processor shall immediately inform the data controller if instructions given by the data controller, in the opinion of the data processor, contravene the GDPR or the applicable EU or Member State data protection provisions.
  3. Carrier integrations. Where the Customer enables a carrier integration in the platform, the Customer instructs Zippendo to disclose personal data contained in consignment and booking data to that carrier so that the carrier can provide transport services. Carriers are independent data controllers of the consignment data they receive: they process it for their own purposes under their own terms and privacy notices, and they are not sub-processors of Zippendo. The Customer's activation of a carrier integration constitutes the Customer's documented instruction for these disclosures. The carriers available in the platform are listed for transparency in Appendix B.
  4. Optional features. Where the Customer activates an optional paid add-on, the Customer instructs processing by the sub-processors listed for that feature in Appendix B.
  5. Support Impersonation. The data controller grants the data processor a general instruction and authorization to access the data controller's account via support impersonation tools solely for the purpose of providing technical assistance, support, maintenance, and troubleshooting as requested by the data controller or as necessitated by critical technical incidents. The data processor shall ensure that such access is restricted to authorized personnel bound by confidentiality, is protected by appropriate technical security measures, and that all impersonation sessions are logged for audit purposes.

5. Confidentiality

  1. The data processor shall only grant access to the personal data being processed on behalf of the data controller to persons under the data processor's authority who have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality and only on a need-to-know basis. The list of persons to whom access has been granted shall be kept under periodic review.
  2. The data processor shall at the request of the data controller demonstrate that the concerned persons under the data processor's authority are subject to the abovementioned confidentiality.

6. Security of processing

  1. Article 32 GDPR stipulates that, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the data controller and data processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.
  2. According to Article 32 GDPR, the data processor shall also — independently from the data controller — evaluate the risks to the rights and freedoms of natural persons inherent in the processing and implement measures to mitigate those risks. To this effect, the data controller shall provide the data processor with all information necessary to identify and evaluate such risks.
  3. Furthermore, the data processor shall assist the data controller in ensuring compliance with the data controller's obligations pursuant to Article 32 GDPR, by inter alia providing the data controller with information concerning the technical and organisational measures already implemented by the data processor pursuant to Article 32 GDPR along with all other information necessary for the data controller to comply with the data controller's obligation under Article 32 GDPR.
  4. The minimum security measures agreed between the parties are set out in Appendix C.2.

7. Use of sub-processors

  1. The data processor shall meet the requirements specified in Article 28(2) and (4) GDPR in order to engage another processor (a sub-processor).
  2. The data processor shall therefore not engage another sub-processor for the fulfilment of the Clauses without the prior specific written authorisation of the data controller, except as provided in Appendix B.
  3. The data processor has the data controller's general authorisation for the engagement of subprocessors listed in Appendix B. The data processor shall inform in writing the data controller of any intended changes concerning the addition or replacement of core or feature-gated sub-processors at least 14 days in advance, thereby giving the data controller the opportunity to object to such changes prior to the engagement of the concerned sub-processor(s). Notification shall be given by email to organisation administrators and by updating https://zippendo.com/legal/subprocessor-list.
  4. Where the data processor engages a sub-processor for carrying out specific processing activities on behalf of the data controller, the same data protection obligations as set out in the Clauses shall be imposed on that sub-processor by way of a contract or other legal act under EU or Member State law.
  5. A copy of such a sub-processor agreement and subsequent amendments shall — at the data controller's request — be submitted to the data controller.
  6. Third-party beneficiary clause. The processor shall agree a third-party beneficiary clause with the sub-processor whereby — in the event the processor has factually disappeared, ceased to exist in law or has become insolvent — the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.
  7. If the sub-processor does not fulfil its data protection obligations, the data processor shall remain fully liable to the data controller as regards the fulfilment of the obligations of the sub-processor.
  8. Objection & Emergency Replacements. If the data controller has reasonable, specific grounds to object to the addition or replacement of a core or feature-gated sub-processor, the data controller must notify the data processor in writing within the 14-day notice period. Objection does not have suspensive effect. If the data controller objects and the parties cannot resolve the objection, either party may terminate the Agreement in writing effective from the date the new sub-processor would take over processing. Detailed rules are in Appendix B. In the event of an acute security threat, force majeure, sub-processor insolvency, or other critical operational disruption threatening platform security or availability, the data processor is authorized to perform an immediate emergency sub-processor replacement, notifying the data controller without undue delay thereafter.

8. Transfer of data to third countries or international organisations

  1. Any transfer of personal data to third countries or international organisations by the data processor shall only occur on the basis of documented instructions from the data controller and shall always take place in compliance with Chapter V GDPR.
  2. Without documented instructions from the data controller, the data processor therefore cannot within the framework of the Clauses:
  • a. transfer personal data to a data controller or a data processor in a third country or in an international organisation;
  • b. transfer the processing of personal data to a sub-processor in a third country;
  • c. have the personal data processed by the data processor in a third country.
  1. The data controller's instructions regarding the transfer of personal data to a third country, including, if applicable, the transfer tool under Chapter V GDPR on which they are based, are set out in Appendix B and the public subprocessor list.

9. Assistance to the data controller

  1. Taking into account the nature of the processing, the data processor shall assist the data controller by appropriate technical and organisational measures, insofar as this is possible, in the fulfilment of the data controller's obligations to respond to requests for exercising the data subject's rights laid down in Chapter III GDPR.
  2. In addition to the data processor's obligation to assist the data controller pursuant to Clause 6.3, the data processor shall furthermore, taking into account the nature of the processing and the information available to the data processor, assist the data controller in ensuring compliance with the data controller's obligations under Article 32-36 GDPR.
  3. Fees. Reasonable assistance included in the Services is provided without charge. Extraordinary assistance — including extensive data-subject-request support, DPIA support beyond standard cooperation, and audit support — may be charged at Zippendo's then-current rates, agreed in advance where practicable.

10. Notification of personal data breach

  1. In case of any personal data breach, the data processor shall, without undue delay after having become aware of it, notify the data controller of the personal data breach.
  2. The data processor's notification to the data controller shall, if possible, take place no later than 48 hours after the data processor has become aware of the personal data breach.

11. Erasure and return of data

  1. On termination of the provision of personal data processing services, the data processor shall be under obligation to delete all personal data processed on behalf of the data controller and certify to the data controller that it has done so, provided that the data controller has been given a reasonable opportunity (at least 7 days prior to deletion) to request an export of its personal data in a standard structured format. Following such period, the data processor shall proceed to delete all personal data unless Union or Member State law requires storage of the personal data.
  2. Deletion timeline. Without prejudice to Clause 11.1, Zippendo will hard-delete personal data processed on the Customer's behalf from active production systems within 14 days of termination of the Agreement or deletion of the Customer's organisation account. Database backup archives, which are maintained solely for disaster recovery and system integrity purposes, are automatically overwritten in accordance with Zippendo's standard backup retention policies, and in any event within a maximum of 30 days following the deletion of the active production data.
  3. Statutory Retention under Danish Law. Notwithstanding Clauses 11.1 and 11.2, Zippendo is authorized to retain billing records, invoice data, and associated transactional metadata (including identifiers of the data controller and invoice recipient) for 5 years from the end of the financial year to which the material relates, strictly as required under Section 12 of the Danish Bookkeeping Act (Bogføringsloven). Such records may be processed and stored by Zippendo's designated third-party billing processor (Stripe Payments Europe, Limited) and accounting processor (Visma e-conomic A/S). Zippendo shall restrict the use of all such retained billing and transaction records exclusively to meeting statutory accounting, bookkeeping, or tax audit obligations, and shall ensure they are securely deleted or anonymized upon the expiration of the 5-year statutory retention window.

12. Audit and inspection

  1. The data processor shall make available to the data controller all information necessary to demonstrate compliance with the obligations laid down in Article 28 GDPR and the Clauses and allow for and contribute to audits, including inspections, conducted by the data controller or another auditor mandated by the data controller.
  2. Procedures applicable to the data controller's audits, including inspections, of the data processor and sub-processors are specified in Appendix C.2.

13. The parties' agreement on other terms

  1. The parties may agree other clauses concerning the provision of the personal data processing service specifying e.g. liability, as long as they do not contradict directly or indirectly the Clauses or prejudice the fundamental rights or freedoms of the data subject and the protection afforded by the GDPR.
  2. Service improvement and anonymised data. The data controller explicitly instructs and authorizes Zippendo to process operational data and transaction logs for the purpose of anonymization and statistical aggregation. Zippendo may use such anonymized and aggregated datasets—where all direct and indirect personal identifiers have been irrevocably stripped—solely to monitor platform performance, ensure reliability, verify billing usage, and improve core integration stability, provided that such use does not re-identify data subjects or violate the confidentiality of the data controller's proprietary business data.
  3. Sensitive data. Special-category data (Article 9 GDPR) is not required for the Services. The Customer must not submit such data except where strictly necessary and lawful.

14. Commencement and termination

  1. Acceptance without signature. The Clauses shall become effective when the Customer creates a Zippendo account or continues to use the Services after this Agreement is published. No signature is required.
  2. The Clauses shall apply for the duration of the provision of personal data processing services.

15. Data controller and data processor contacts/contact points

  1. The parties may contact each other using the following contacts/contact points:
  • Data processor (Zippendo): [email protected].
  • Data controller (the Customer): the organisation administrator email addresses registered in the Customer's Zippendo account.