GDPR Article 28 β€’ EU Compliant β€’ Romanian Law

Data Processing Agreement

Data Processing Agreement (DPA) in compliance with the General Data Protection Regulation (GDPR) and applicable Romanian law

Processor
Regio Development SRL
Tax ID: 44161343
Reg. No.: J26/706/2021
Address
Str. Dealul Rotund no. 5
Sovata, Romania
contact@regio-development.net
Date: 15 September 2025
Version 1.0
GDPR & Romanian Law Compliance
Legal requirements met when processing personal data

Regulations Followed

GDPR (EU) 2016/679Law 190/2018 (Romania)Law 506/2004ISO 27001 Framework

Guaranteed Rights

Right of access
Right of rectification
Right of erasure
Data portability
1. Definitions

"Controller" = Regio Development SRL, in its capacity as a SaaS digital signage service provider.

"Processor" = Regio Development SRL, in its capacity as processor of personal data on behalf of its customers.

"Personal data" = any information relating to an identified or identifiable natural person.

"Processing" = any operation performed on personal data, including collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

"GDPR" = Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.

2. Subject of the Agreement

This Agreement sets out the obligations and responsibilities of the parties in connection with the processing of personal data within the provision of SaaS digital signage services.

The Agreement governs processing carried out by the Processor on behalf of and for the Controller, in line with the latter's documented instructions.

Purpose of processing: provision of digital signage services, including content management, screen performance monitoring and platform usage analytics.

3. Nature and Purpose of Processing

Categories of Data Processed

Identification data: first name, last name, role within the organisation
Contact data: email address, phone number
Authentication data: username, hashed passwords
Technical data: IP addresses, access logs, browser information
Usage data: platform interactions, user preferences
Billing data: company information, tax identification (for legal entities)

Purposes of Processing

Provision of digital signage services
Authentication and user management
Platform performance and security monitoring
Technical support and service-related communications
Billing and contract management
Compliance with legal obligations

Categories of Data Subjects

Platform admin users (Controller's employees)End users of the digital-signage systemsContact persons for billing and commercial communications
4. Processor's Obligations

Confidentiality and Security

Processes the data only in accordance with the Controller's documented instructions
Ensures that personnel authorised to process the data are committed to confidentiality
Implements appropriate technical and organisational measures for data security
Uses encryption for data in transit and at rest

Subprocessing

Does not engage another processor without the prior written authorisation of the Controller
Where subprocessing is authorised, signs a contract that imposes the same data-protection obligations
Remains fully liable to the Controller for the performance of the subprocessor's obligations

Data-Subject Rights

Assists the Controller in fulfilling its obligation to respond to data-subject requests
Facilitates the exercise of rights: access, rectification, erasure, restriction, objection, portability
Notifies the Controller within 24 hours of any request received directly from a data subject
5. Security Measures

Technical Measures

Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
Passwords hashed with strong algorithms (bcrypt/argon2)
Two-factor authentication for administrative accounts
Continuous monitoring and intrusion detection (SIEM)
Encrypted backups with periodic restore testing
Network segregation and role-based access control
Automated security updates for critical systems

Organisational Measures

Documented security policies, reviewed annually
Periodic training for personnel with access to personal data
Incident-response and notification procedures
Quarterly internal security audits
Need-to-know-based access control
Secure data-destruction procedures
Maintenance of a record of processing activities
6. Personal Data Breaches

The Processor will notify the Controller of any personal data breach within 24 hours of becoming aware of it.

The notification will include: the nature of the breach, the categories and approximate number of data subjects, the categories and approximate number of records affected, and the measures taken to remedy the breach.

The Processor will cooperate with the Controller in investigating the incident and implementing remedial measures.

A detailed incident report will be issued within 72 hours, including causes, impact and preventive measures implemented.

7. International Transfers

Personal data is stored and processed exclusively within the European Economic Area (EEA).

Servers are located in certified data centres in Romania and other EU member states.

If a transfer of data outside the EEA becomes necessary, the Processor will:

β€’ Obtain prior written authorisation from the Controller

β€’ Ensure adequate safeguards through Standard Contractual Clauses approved by the European Commission

β€’ Implement supplementary protection measures in line with EDPB recommendations

8. Auditing and Compliance

The Processor will make available to the Controller all information necessary to demonstrate compliance with the obligations set out in this Agreement.

The Controller, or an auditor mandated by the Controller, has the right to carry out audits, including inspections at the Processor's premises, with at least 30 days' notice.

Audits will take place during normal business hours and will not unduly affect the Processor's activities.

Audit costs are borne by the Controller, except where major non-conformities are identified.

The Processor will remedy any non-conformity identified within the agreed timeframe, but no later than 90 days.

9. Data Retention and Deletion

Retention Periods

Data TypeRetention PeriodAction
Authentication and user account dataDuration of the contract + 30 days for closing activitiesAutomatic deletion on expiry
Access and security logs12 months from generationAnonymisation or deletion
Billing data10 years per Romanian accounting lawSecure archival, then deletion
Backups30 days for daily, 90 days for monthlyAutomatic deletion with overwrite

Deletion Process

1
On termination of the agreement, the Processor will delete or return all personal data
2
Deletion is carried out within 30 days of termination
3
Written confirmation of complete deletion, including from backups, will be provided
4
Data may be retained only to the extent necessary to comply with legal obligations
10. Liability and Damages

The Processor is liable for damage caused by processing only where it has failed to fulfil its obligations under this Agreement or has acted outside or against the Controller's lawful instructions.

The Processor's liability is limited to direct damages up to the value of the annual contract, except for:

β€’ Wilful or grossly negligent breaches

β€’ Breaches of confidentiality and data security

β€’ Sanctions imposed by supervisory authorities

In the event of a joint action against the Controller and Processor, each party will be liable in proportion to its degree of responsibility.

Final Provisions

Amendments and Updates

This agreement may be amended only by written agreement of both parties.

Legislative updates will be incorporated automatically, with at least 30 days' prior notice.

The current version is permanently available at:regiodisplay.net/legal/dpa

DPO Contact

contact@regio-development.net
+40 759 205 629
Str. Dealul Rotund no. 5
Sovata, Romania
GDPR Article 28 Compliant
Romanian Law
Data in the EU
ISO 27001 Framework