XFXray Flow
Legal Compliance

Data Processing Agreement (DPA)

For agencies and enterprise customers who require a formal agreement regarding the processing of personal data.

Agreement Overview

Scope

Processing of Make.com Blueprints and associated metadata for documentation generation.

Data Location

Australia (Vercel Network) / Australia (Operational Base)

Authorized Sub-processors

EntityPurposeLocation
Vercel Inc.Cloud Hosting & Serverless FunctionsAustralia
Supabase Inc.Authentication & DatabaseAustralia
Stripe Inc.Payment ProcessingUSA
PostHog Inc.Product Analytics (EU-hosted, opt-in)EU (Germany)

Subprocessor Notification & Change Policy

The following policy governs how we notify you of changes to subprocessors, as required by Article 28 GDPR and APP 8:

  • Advance Written Notice: We will provide at least 30 days' written notice (via email to the registered contact and in-app notification) before authorising any new subprocessor or materially changing the scope of an existing subprocessor's processing activities.
  • Right to Object: The data controller (you) may object to a new subprocessor within the notice period by written notice to [email protected]. If you object, we will either (a) refrain from engaging the subprocessor for your data, or (b) provide you the option to export your data and terminate the agreement with a pro-rata refund of prepaid fees.
  • Due Diligence: Before engaging any new subprocessor, we conduct a security and privacy assessment including: SOC 2 Type II or ISO 27001 certification review, execution of a data processing agreement with the subprocessor, and verification of appropriate data transfer mechanisms (Standard Contractual Clauses for international transfers).
  • Subprocessor Register: The current register of subprocessors is maintained in the table above and at xrayflow.io/security. Changes are reflected within 5 business days of execution.
  • Annual Review: We review all subprocessors annually for continued compliance, necessity, and proportionality. Subprocessors no longer required are removed within 30 days.

Execute this DPA

Request the standard Data Processing Agreement via email, and our team will send you a countersign-ready copy.

Request DPA via Email

Version 1.0 (June 2026) — Custom countersign required

TLS 1.3 EncryptionAll data in transit encrypted with TLS 1.3
Stripe PCI-DSS Level 1Payments processed by Stripe (PCI-DSS Level 1 certified)
Hosted on Vercel (SOC 2, ISO 27001)Vercel infrastructure: SOC 2 Type II, ISO 27001 certified
GDPR & CCPA CompliantFull GDPR Art. 28 DPA available, CCPA rights supported

© 2026 Xray Flow. Not affiliated with Make.com.

All rights reserved. XrayFlow is a product of PirateApeStudios (ABN 47 340 546 246)

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