LEGAL
ZTPipe Data Processing Agreement
Last updated: 7 November 2026
This Data Processing Agreement (the “DPA”) sets out the conditions on which Packet Pilot LLC (“we”) processes personal data on behalf of a customer (“you”) in providing ZTPipe (the desktop app, the customer portal, the license service, the network check service and Proof; the “Service”). This DPA forms part of the ZTPipe Terms of Service and is intended to meet the requirements of Article 28 of the GDPR. If you would like to sign a separate written agreement, please contact us at the address in Article 10.
Article 1 (ZTPipe’s design and the scope of this DPA)
- ZTPipe handles the content of your mail (subject, body, attachments and recipients), your encryption keys and your contacts only on your devices, and does not send them to our servers. We do not process them (Privacy Policy, sections 1 and 2).
- This DPA applies to the personal data that reaches our servers when you use the Service and that we process as a processor.
- Data for which we are the controller — the portal accounts of your administrators and users, billing contacts and other data we handle to manage the contract, authenticate users and bill you — is covered by the Privacy Policy.
- The terms “personal data”, “controller”, “processor”, “processing” and “personal data breach” have the meanings given in Article 4 of the GDPR.
Article 2 (Details of the processing)
| Personal data | (1) Optional notes that your administrator attaches to each license (such as the user’s name). (2) License check data: a matching value calculated on the device from the user’s email address and serial number (the email address itself is not sent), a device identifier derived from the device’s signing key, the OS, the app version and the time of the check. (3) Hashes of messages and attachments when a Proof is added (their content is not sent). |
|---|---|
| Purposes | Checking licenses and the number of devices, issuing Proofs, and providing the Service. |
| Nature of the processing | Storage, matching, obtaining time-stamps (hashes only) and other operations needed for the functions of the Service. |
| Duration | For the term of the contract and until deletion under Article 7 is complete. |
| Data subjects | Your officers and employees, and the users to whom you assign licenses. |
We are designed so that we do not hold email addresses or device names behind the matching values and device identifiers, and we keep the personal data we process to a minimum.
Article 3 (Our obligations)
- We process personal data only on your documented instructions (including the Terms of Service and your use of the Service itself). If the law requires us to process it otherwise, we will inform you in advance unless the law prohibits this.
- We bind the staff who handle personal data to confidentiality and give access only to those who need it.
- If we consider that an instruction from you infringes the GDPR or other applicable law, we will inform you immediately.
- We do not use your personal data for any purpose other than those set out in this DPA, and we do not sell it to third parties.
Article 4 (Sub-processors)
You agree that we may use the following sub-processors.
| Sub-processor | Purpose | Location |
|---|---|---|
| Amazon Web Services | Hosting of the Service (Tokyo region) and sending email (Amazon SES) | Japan |
| Stripe | Credit card payment processing. Card numbers are collected directly by Stripe and do not pass through our systems. | United States and others |
The Proof time-stamping service (PP-TSA) is operated by us and is not a sub-processor. We impose on each sub-processor, by contract, obligations substantially equivalent to those in this DPA, and we are responsible for its acts as if they were our own. If we add or change a sub-processor, we will publish the change on this page and notify you at least 30 days before it takes effect. You may object on reasonable grounds within 14 days of the notice. If we cannot reach agreement, you may terminate the contract for the services that require that sub-processor.
Article 5 (Assistance with data subjects’ rights)
If a data subject makes a request to us to exercise their rights, we will not respond on our own judgement but will forward the request to you without delay (unless the law requires us to respond directly). We will assist you, to a reasonable extent, through the functions of the portal (such as editing license notes and releasing device slots) and technical support, so that you can respond to requests for access, rectification, erasure, restriction of processing, objection and data portability.
Article 6 (Notification of personal data breaches)
If we become aware of a personal data breach within the scope we control, we will notify you without undue delay. To the extent known, the notification will describe the nature of the breach, the categories and approximate number of personal data records affected, the likely consequences, the measures we have taken or plan to take, and our contact point. Where you, as controller, must notify a supervisory authority (as a rule within 72 hours of becoming aware of the breach where the GDPR applies), we will assist you to a reasonable extent by providing the information you need.
Article 7 (Deletion at the end of the contract)
When the contract ends, we delete the personal data we processed once 30 days have passed after the end of the contract (Privacy Policy, section 11). Information that we are required by law to keep is excluded. The data on your devices (messages, keys and contacts) is not on our servers; it is removed when you delete the ZTPipe data on your devices. Personal data contained in backups is deleted when the retention period of those backups expires.
Article 8 (International transfers)
We process personal data in Japan (AWS Tokyo region). Transfers from the European Economic Area to Japan can be made without separate standard contractual clauses, because Japan has an adequacy decision from the European Commission. For payment processing, some personal data may be transferred to Stripe (United States). Stripe participates in the EU-U.S. Data Privacy Framework and also offers transfer mechanisms based on standard contractual clauses. We make no other transfers to third countries. If one becomes necessary, we will notify you in advance and put a lawful transfer mechanism in place.
Article 9 (Technical and organisational security measures)
To meet the standard required by Article 32 of the GDPR, we take the following measures:
- Encryption of data in transit (TLS) and at rest
- Protecting signing keys, Proof keys and other secrets with key management services (AWS KMS / Secrets Manager), and not placing them in source code or configuration files
- Least-privilege access and role-based access control
- Two-factor authentication for every portal account
- Separation of data for each customer
- Recording and preserving audit logs
- Regular backups and verification of the restore procedure
- Restricting direct access to the production database
- Data protection by design (mail content, keys and contacts are not sent to our servers, and the personal data we handle is kept to a minimum)
Article 10 (Audits, evidence and contact)
- We will provide, at your reasonable request, the information needed to demonstrate compliance with this DPA.
- You may request an audit no more than once a year, with at least 30 days’ prior written notice. Audits must be conducted in a manner and at times that do not unduly disrupt our business, and you bear the cost of the audit. Where we can provide a third-party assessment report, we may provide it instead of an audit.
- For questions about this DPA, or to request a signed written agreement, please contact:
Packet Pilot LLC (Packet Pilot合同会社) — product.support@packet-pilot.net