General terms of service and platform usage for SportFinder.
These general terms govern the use of the SportFinder platform that SPORTFINDER SPRL makes available to its partners (hereinafter the “Partner” or the “Partners”).
The platform is administered by SPORTFINDER SPRL, registered with the BCE under No. BE0722.563.391 and whose registered office is located at Rue des Comparçonniers 55, 6060 Charleroi, Belgium * (hereinafter the “SportFinder” or the “Platform”).
The parties bound by these general terms are SportFinder and the Partners who subscribe to SportFinder's services, in accordance with the provisions described in this document (hereinafter the “Parties”).
1. Definitions
- Partner.
- Sports centers, affiliated clubs or sports coaches maintaining a business and contractual relationship with SportFinder.
- Platform.
- Represents the website of SportFinder (www.sport-finder.com) and all the services offered by it.
- Services.
- The services offered by SportFinder on its website www.sport-finder.com and explicitly mentioned in this agreement.
- Stripe
- A technology company developing an online economic infrastructure enabling it to accept payments and manage its online activity.
- Payout.
- Refers to the act of paying the amounts due to partners for any purchase made through the platform.
- User
- any person using the services available on the platform.
- Commission.
- Represents the percentage of the amounts collected by SportFinder in relation to the services provided by the partner to users, representing part of SportFinder's remuneration.
2. General description of SportFinder's services
SportFinder, whose mission is the general promotion of sport, has developed and owns all rights to the software gathered on the platform, including:
- A sports directory
- A reservation system enabling Users to manage and pay for their reservations and other services offered by the Partner
- A management software enabling the operational management of the sports center (hereinafter “SportFinder ERP” or “management software”), including reservations made by Users on the Platform or reservations entered directly by the Partner.
The management software and reservation system are directly subject to and covered by these general terms and conditions.
The sports directory serves, among other things, to promote the Partners' offers. SportFinder reserves the right to modify or discontinue this service without giving Partners any right to claim.
3. Obligations des parties
SportFinder agrees to
- Provide a management software specially designed for the sports sector, enabling operational management of the sports center/club.
- Provide a reservation system allowing Users to make reservations for the services offered by the Partner.
- Assist the Partner during the first month of the contract for any questions related to the platform, its implementation and operation.
- Transfer the funds received to the Partner for goods and services provided by the Partner.
- Ensure the Partner complies with GDPR on the platform.
- Ensure the Partner's compliance with Belgian legislation governing the services available on the platform.
The Partner agrees to:
- Understand and comply with the terms of use of SportFinder, of which the Partner has been previously informed.
- Respect and comply with all agreements contained in this document.
- Have the technical elements necessary for the proper functioning of the service: up-to-date operating system, Internet access, up-to-date web browser.
- Honor all reservations made by Users regarding the Partner's services reserved on the Platform.
-
Keep the availability of its reservation-offered services up to date.
The following are concerned: occupancies, reservations, sales and stock.
The Partner agrees to exhaustively record all occupancies (reservations) accepted outside the platform on the platform via the management software or to render the services or resources (e.g., fields) non-bookable.
In order to avoid negatively impacting the experience and satisfaction of end Users caused by: double bookings or reservations not honored. - Ensure that any user performing an action on the platform's management software, SportFinder ERP, has sufficient authority to act on behalf of the Partner, thereby exonerating SportFinder from any dispute arising from the Partner's conduct or negligent action.
- Pay SportFinder the agreed price in accordance with the financial terms described in the special conditions detailed in the signed agreement.
- Not to dispute any financial transactions concerning the remuneration of SportFinder as agreed in accordance with the financial terms of these conditions and described in the special conditions detailed in the signed agreement.
- Ensure that any use and handling of the platform is performed by a natural person employed by the Partner or a professional collaborator of the Partner. The use of any type of tool, notably robotic or software, whether its own or that of a third party, is strictly forbidden unless explicit written consent is given by SportFinder by email.
- Not transfer the rights and/or obligations acquired under these Terms and Conditions to a third party, including the subrogation of its contractual position, without the express written authorization of SportFinder.
- Do not use the services to engage in activities contrary to the law, to good morals, to public policy, or use the services for illegal, prohibited or harmful purposes to the rights and interests of third parties; SportFinder declines any liability that may result therefrom.
- Comply with European and national data protection regulations (GDPR) and be aware that certain information is confidential and that disclosure of such information may lead to serious penalties. More details at point 8. Confidentiality.
- Do not encourage Users to cancel their online bookings and to pay on site. This has a direct negative financial impact on SportFinder and undermines the continuity of its mission.
- Do not circumvent the system to avoid paying the commission to SportFinder.
- Acknowledge invoices generated by the Platform in its name and addressed directly to Users for goods and services booked via the Platform.
4. Authorization and consent of the Partner
The Partner expressly authorizes SportFinder to publish in real time and to manage online sales and the collection of payments for the products and services offered by the Partner to all Users of the Platform.
To this end, the Partner expressly undertakes that all sports products and services marketed online will be offered on the SportFinder platform.
Similarly, the Partner authorizes SportFinder to display information and specific conditions to the Partner's user such as: special conditions, internal regulations, Partner's general terms, Partner's general service terms, subscriptions, discounts, promotions, membership, etc.
The Partner grants SportFinder the right to issue invoices in its name to the Users in relation to the products and services reserved via the Platform.
Finally, the Partner authorizes SportFinder to use non-personal data for purely statistical purposes that may contribute to the improvement of the Platform and of the service rendered.
5. Duration
Unless otherwise stated in the special conditions detailed in the signed agreement:
This agreement is entered into for an indefinite term effective from the date of its signature. Each party may terminate it by giving 30 days' notice served by registered mail, taking effect on the third business day after its dispatch.
6. Financial terms
6.1. Financial terms relating to SportFinder
Costs associated with the services provided and the payment method are detailed in these general terms and conditions.
6.2.1. Subscription
Unless otherwise stated in the special terms detailed in the signed agreement, the services related to the management software , SportFinder ERP, will be billed monthly in advance. The Partner makes payment under the contract terms by direct debit or by bank transfer. In case of refund, a delay of more than 30 days, or non-payment of invoices, SportFinder may suspend all or part of the Services at any time and without prior notice.
6.2.1. Commission.
In addition, SportFinder handles online sales and the processing of payments for reservations and sporting offers for the Partner on the booking system, collecting financial and management commissions in accordance with the financial and payment terms as detailed in the agreement.
SportFinder will bear the costs inherent to bank payments (Stripe, Bancontact, transfers of funds to the Partner, ...).
SportFinder reserves the right to apply a minimum additional 1% fee (service charges included) in the event that the commission net of transaction fees is less than 1%.
The commission charged by SportFinder is fully refunded in the case of a full and indivisible refund of an online transaction.
6.2.3. Service fees
SportFinder reserves the right to charge a service fee to the end user or to the Partner. SportFinder states a preference that the prices displayed to Users be the same as the prices offered by the Partner. Nevertheless, in order to guarantee service quality and the continuity of its mission, SportFinder reserves the right to charge a service fee (fixed or %).
The destination of its service fees (to the User or Partner) is at the Partner's discretion and may be changed each month. The change takes effect on the first day of the following month.
SportFinder reserves the right to modify the service fees at any time and will inform the Partner and the Users of any change in service fees before they take effect. Changes to service fees will not affect sales made through the Platform prior to the effective date of this service fee modification.
The Partner cannot claim any portion or all of the service fees collected by SportFinder.
6.3. Financial terms relating to the Partner.
SportFinder will transfer the amount due to the Partner after deduction of its commission and service fees, the rate of which is detailed in the special conditions described in the agreement signed under the bank account number provided by the Partner to Stripe.
The Partner's Payout will be made, unless otherwise stated in the platform configuration by the partner or the signed agreement, on a weekly basis. Each Payout will be associated with a document listing all reservations made with the Partner.
SportFinder would like, in the future, to provide partners the ability to manually manage Payouts from the management software , or to autonomously configure their payout frequency.
6.4. Taxation
All taxes arising from the performance of these General Terms and Conditions shall be borne by each Party.
6.5. Cancellation and refund
6.5.1. Cancellation by the User
The refund amount related to a User's withdrawal period for a reservation is to be defined by the Partner.
Unless otherwise stated, the following deadlines apply.
- More than 48 hours before the start of the reservation: the user will be refunded the full purchase amount.
- 48 hours or less before the start of the reservation through the start of the reservation: the user will not be refunded.
SportFinder reserves the right to move the time slot of a reservation in order to avoid cancellation under the following conditions:
- The preceding clause is respected or with the Partner's explicit agreement.
- The user has given their consent.
6.5.2. Cancellation by the Partner
Costs borne by SportFinder
In the event of Platform unavailability or any other errors attributable to SportFinder, the fees related to the payment and its refund will be fully borne by SportFinder.
Assumed error
- Data error: the data were not correctly recorded by SportFinder, the data have been modified by SportFinder.
- Platform programming bug: any non-conforming behavior that allowed the double use of a resource.
Platform unavailability SportFinder will bear any cancellation related to a double booking resulting from prolonged and uninterrupted unavailability. An unavailability is considered prolonged if it lasts more than 120 minutes.
Costs borne by the Partner
The following points imply that the Partner will bear the transaction fees charged by the Stripe payment method.
-
Encoding error
The dates are incorrect, price error on a product. -
Double booking
Platform reservations are prioritized; all reservations accepted outside the Platform (e.g., by phone) must be entered on the Platform (making the resources unavailable). -
Schedule/configuration error
All cancellations due to a modification of the Partner's schedule not communicated to SportFinder, rendering the resource unavailable. -
Resource unavailable
The resource is not available and is not marked as such
7. Complaints and disputes
-
User complaint against a Partner
Any complaint from Users relating to the services provided by the Partner shall be forwarded to the concerned Partner. The Partner agrees to provide SportFinder as soon as possible, and at the latest within eight (8) days from the transfer of the request by SportFinder, a detailed response with, where applicable, a proposal for compensation to the User (damages, non-performance, non-delivery, accident, injury, …). -
User complaint against SportFinder
Any complaint from Users relating to the services provided by SportFinder and shared with the Partner will be forwarded to SportFinder by the Partner via email. This, in order to improve the services provided by SportFinder. -
Complaint by a Partner against SportFinder
Any complaint from a Partner relating to the services provided by SportFinder will be transmitted to SportFinder via the communication channels defined in this agreement and aiming to respect common courtesy rules. -
Stripe payment method disputes
A dispute is requested by the User. All payment-related disputes are handled directly in Stripe's dashboard and automatically incur dispute fees of €15 imposed by Stripe. -
Dismissal of the dispute
The payment was indeed due by the User and the dispute fees are refunded. -
Dispute charged to the Partner
The Partner is responsible for the origin of the dispute and will alone bear the entirety of the dispute fees as well as the initial payment, clause 8.1.4 (double payment by a user - on-site and on the platform, double booking, …) -
Dispute charged to SportFinder
SportFinder is responsible for the origin of the dispute and will alone bear the entirety of the dispute fees as well as the initial payment, clause 8.1.4 -
Shared liability
SportFinder and the Partner will share the dispute fees at 50% each. The fees related to the initial payment will remain borne by SportFinder.
8. Confidentiality
The parties mutually undertake to respect vis-à-vis third parties the confidential nature of all data and information relating to the business affairs of the other party, the confidential nature of which has been expressly mentioned or results from the nature of the information, and of which they themselves, their staff or the third parties they have engaged, became aware during the conclusion and/or execution of this Agreement.
The parties will bring to the attention of their staff and/or third parties working for them that they cannot in any way, directly or indirectly, verbally, in writing or otherwise, disclose to third parties any confidential data relating to or arising from their relationship with the other party, without the prior written consent of the other party.
The confidentiality obligations arising from this article apply to data communicated even before the signing of this contract. Each party undertakes to ensure that its staff comply with the confidentiality obligation set forth in this Article and will assume full responsibility in case of breach by its staff or any of its subcontractors.
The Partner undertakes to process data collected within the framework of its mission in compliance with the law of 8 December 1992 relating to the protection of privacy and the law of 13 June 2005 on electronic communications.
The data collected by the Partner within the framework of its Partnership with SportFinder may under no circumstances be communicated to third parties without the prior written consent of SportFinder. The Partner shall however have the right to use these data in order to carry out its mission, in compliance with applicable legal provisions.
9. Data Protection.
9.1. Processing of the personal data of signatories and employees.
Under
Belgium Article 8, 1° of the ECHR [1] and by Article 22 of the Constitution,
Europe Regulation (EU) 2016/679 ("General Data Protection Regulation," hereinafter GDPR), published on 4 May 2016 [2],
the Parties, on the basis of legitimate interests arising from the execution of the services rendered and as personal data are necessary to provide said services, SportFinder may process the personal data of the administrator of the Partner and of its partners on systems and files duly reflected in the journal of processing. All of this is carried out in strict compliance with the applicable data protection regulations.
By signing these General Terms and Conditions, the Parties consent to the processing of their personal data and confidential data under the terms and modalities indicated herein.
The Partner is informed that the contact details of the administrator and its partners will be processed by SportFinder to enable the development, execution and monitoring of the service provision relationship concluded; the legal basis for the processing is the performance of a contract and the legitimate interest of both Parties in being able to satisfy these purposes; the data are retained for the duration of the aforementioned relationship and, even after its end, until the expiration of the liabilities arising therefrom.
The data being processed will be contact details. Personal data provided or collected in connection with the execution and performance of these General Terms and Conditions will not be shared with third parties, except as required by law.
The personal data accessible will not be subject to international transfers.
Data subjects may withdraw their consent and exercise their rights of access, rectification, erasure, objection, restriction, portability, and not to be subject to automated individual decision-making, by writing to the registered office of SportFinder providing a photocopy of a government-issued certificate and specifying the request.
If one of the parties believes that its right to data protection has been violated, it may file a complaint with the Belgian Data Protection Authority https://www.autoriteprotectiondonnees.be/.
Annex- European Convention on Human Rights
- Regulation (EU) 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: https://eur-lex.europa.eu/legal-content/FR/TXT/HTML/?uri=CELEX:32016R0679&from=EN.
9.2. Processing of personal data for which SportFinder is the data controller.
SportFinder is the data controller of the personal data of users registered on the Platform and once said data are received by the Partner, the Partner will assume responsibility for them and apply the data protection laws in force to said database.
The personal data of users will be shared with the Partner for the exclusive purpose of managing reservations made by the Users on the Platform. The Partner also undertakes to inform users in accordance with the provisions of Article 14 of the GDPR and, where applicable, to obtain their consent to transmit commercial information to the users.
9.3. Processing of personal data for which the Client is the data controller.
The Partner shall be responsible for the personal data of any User whose data have been collected directly by the Partner and thus managed on the management software ; where SportFinder will acquire the status of subcontractor. Consequently, the Parties agree to sign a data processing agreement attached to these General Terms of Service as ANNEX I.
10. Liability
SportFinder will apply best practices in security procedures and data recovery and will make its best efforts to provide an optimal and high-quality service to the Partner.
SportFinder will not be liable for network failures attributable to telephone and/or telecommunications operators. Its liability cannot be engaged in particular for: interference due to atmospheric conditions, lack of coverage of the user's mobile terminal, failures of the user's terminals, failures of the network power supply by the operator(s), improper or fraudulent handling of the user's terminals or computer or telecommunications equipment, power outages, suspension by the internet service provider or the network provider.
SportFinder will not be responsible for correcting anomalies attributable exclusively to the Client's computer or computers used by the Client, deficiencies in the surrounding working conditions, or failures of the main AC network or its variations or the communications provider which, consequently, have no causal link to the request.
The liability of SportFinder under these general terms and conditions shall be limited to the sum of all amounts paid by the client during the six (6) months preceding the occurrence of the damaging event, for each incident and for the total of all incidents occurring during that period.
11. Intellectual and Industrial Property
All elements of the software and platform are the exclusive property of SportFinder, with all rights reserved. None of the elements may be modified, copied, distributed, framed, reproduced, downloaded, extracted, displayed, published, transmitted or sold in any form or by any means, in whole or in part, without the prior written consent of SportFinder. To the extent that the user has the right to use the offered service, SportFinder grants a license to use the software, provided that all notices regarding copyright and intellectual property remain intact. Any other use is strictly prohibited.
12. Termination
Notwithstanding the foregoing, each party may terminate this Agreement without notice or indemnity for a serious cause. The following breaches are considered serious causes.
- Non-compliance with the confidentiality obligation imposed by Article 8,
- Any damage to SportFinder's brand image and to its intellectual property rights,
- Non-compliance with the applicable privacy protection laws,
- Repeated gross negligence in verifying the information transmitted to SportFinder by the Partner.
- Any serious or repeated breach of the provisions of Article 3.
Termination for any reason of these General Terms of Service does not relieve the Parties of paying the sums already accrued for the benefit of the other party, up to the moment of the effective termination of these General Terms of Service. These amounts must be paid in all cases in accordance with the payment criteria established. However, in the event of termination of these General Terms of Service for breach of contract by the Partner, all sums accrued up to that time shall automatically become due in advance.
If the Partner fails to meet its payment obligations, SportFinder may, in addition to the amounts due, claim as damages the maintenance installments contracted by the Partner, up to the expiration of the contract. This compensation shall not exclude any other claims for damages suffered by SportFinder due to any other non-compliance by the Partner.
12. Changes to the Services
SportFinder reserves the right to modify the services to adapt them to: (a) the market's technical evolution; (b) any technical, functional and operational improvements that enable an improvement in the provision of these services; (c) changes in laws, regulations and standards applicable to the provision of these services and/or related aspects.
13. Annex
These General Conditions constitute the entire contract between the Parties and supersede any prior communications or documentation relating to its subject matter.
The following annexes are an integral part of these General Conditions:
- ANNEX I: Data Processing Service Agreement
14. Miscellaneous
The invalidity of a clause of this contract shall not affect the validity of the other clauses.
The parties undertake, in such case, to negotiate in good faith the adoption of a new clause that pursues the same objective as the invalid clause and will, to the extent possible, have equivalent effects, in order to restore the contractual balance.
The agreement shall be reevaluated by the Parties every 12 months, to adapt, if necessary, the procedures or modalities of their collaboration. However, no operational or procedural change shall occur that would transform the content of this Agreement in such a way that the collaboration between the parties would be affected.
15. Governing Law and Jurisdiction.
This agreement is governed by Belgian law.
Any dispute relating to these General Terms of Service shall be resolved exclusively by the French-speaking Courts of the judicial district of Hainaut.
© SPORTFINDER S.P.R.L. 2019. All rights reserved.ANNEX I: Data Processing Service Agreement
The services ordered by the Partner through the management software involve access to and processing by SPORTFINDER SPRL (hereinafter the data processor or processor) in various automated file systems owned by the Partner (hereinafter the data controller or the controller), governed by the following clauses.
Purpose of processing and identification of the information concerned
By signing these terms and conditions, the Partner authorizes SPORTFINDER SPRL as the data processor to process the personal data necessary to provide data processing services by contracting the management software or reservation system.
The processing will in particular consist of managing and maintaining the software application under contract, management software, and consequently access to the personal data managed by the Partner via the management software.
To perform the service arising from compliance with the object of this order, the data controller provides SPORTFINDER SPRL with the information described below:
- Type of data subject: customers, employees and suppliers.
- The processing carried out by SPORTFINDER SPRL is limited to the following information: identification data, personal characteristics, social circumstances, employment information, financial, economic and insurance information, real estate and service transactions, and login credentials.
Obligation of the subcontractor.
The data controller and all of its personnel undertake to:
- Use the personal data subject to the processing exclusively for the purposes of the order specified in the CGV. Under no circumstances may the data be used for its own purposes or for purposes other than those expressly stated.
- Process the data in accordance with the data controller's instructions.
- If the subcontractor considers that any instruction infringes the GDPR or any other provision, the subcontractor shall immediately inform the data controller.
- Keep a written record of all categories of processing activities carried out by the data controller, containing:
- The name and contact details of the data processor(s) and of each data controller for whom the subcontractor acts on behalf of and, where applicable, the representative of the data controller or the subcontractor and the data protection officer.
- A description of the types of processing carried out by the Subcontractor.
- If applicable, transfers of personal data to a third country or an international organization.
- A general description of the appropriate technical and organizational security measures concerning:
- Secure data storage.
- The ability to continuously ensure the confidentiality, integrity, availability and resilience of the processing systems and services.
- The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
- A process for testing, evaluating and regularly assessing the effectiveness of the technical and organizational measures to ensure the security of processing.
- Do not disclose data to third parties, except with the express authorization of the data controller in cases permitted by law. The processor, where applicable, may share the data with other processors working under the same data controller, in accordance with the data controller's instructions. In such a case, the data controller identifies in writing and beforehand the company to which the data must be disclosed, the data to be disclosed and the security measures to be applied to the said procedure.
- If the processor must transfer personal data to a third country or an international organization, under Union law or the law of a Member State, the processor informs the data controller of this legal obligation before processing, unless such law prohibits such information for important reasons of public interest.
- The Subcontractor may subcontract the provision of the services undertaken, provided that this has been previously authorized by the data controller. In such cases, the Subcontractor shall inform the data controller in writing of the identity of the subcontractors. Furthermore, the Subcontractor shall inform the data controller of any changes concerning the subcontractors, and the data controller shall have a period of 15 days to submit reasoned objections in writing. The Subcontractor may carry out such subcontracting only if the data controller has not opposed it within the said period. The subcontractor, who will also have the status of a sub-processor, also commits to comply with the obligations set out in this document for the subcontractor and the instructions provided by the data controller. The Subcontractor is responsible for governing the new relationship so that the new sub-processor is subject to the same conditions (instructions, obligations, security measures) and has the same formal requirements as the said party with regard to proper processing of personal data and the protection of the rights of data subjects. In case of non-compliance by the subsequent sub-processor, the initial Subcontractor shall remain fully responsible to the Data Controller for the performance of the obligations.
- Fulfill the duty of confidentiality with respect to all personal data accessed in the course of the contracted services.
- Ensure that persons authorized to process the personal data are expressly bound in writing to respect confidentiality and to comply with the corresponding security measures.
- Make the documentation evidencing GDPR compliance available to the controller.
- Ensure the necessary training on personal data protection for persons authorized to process personal data.
- The subcontractor must inform the data controller of any personal data breach for which it is responsible, immediately and without undue delay from the moment it becomes aware of the breach, when it is likely that the breach involves a high risk to the rights and freedoms of natural persons. The notification must be provided in clear and simple language and must include at least:
- Explain the nature of the data breach.
- Provide the name and contact details of the data protection officer or another contact person from whom further information can be obtained.
- Describe the potential consequences of the personal data breach.
- Describe the measures adopted or proposed to remedy the personal data breach, including, where applicable, the measures adopted to mitigate potential negative effects.
- Assist the data controller in preparing the legally required data protection documents, where applicable.
- Assist the controller in preparing preliminary consultations with the supervisory authority, where applicable.
- Provide the data controller with all information necessary to demonstrate compliance with the obligations set out in Article 28 of the GDPR.
- Implement the technical and organizational measures necessary to ensure ongoing confidentiality, integrity, availability and resilience of processing systems and services. The subcontractor provides sufficient guarantees to implement appropriate technical and organizational measures, in accordance with the requirements of Regulation (EU) 2016/679 and Organic Law 3/2018 of 5 December on data protection and the guarantee of digital rights, ensuring the protection of data and the rights of data subjects. The security measures implemented by the Subcontractor shall be those appropriate to the risk level, in accordance with the risk analysis carried out by the Subcontractor.
- The subcontractor will assist the data controller in fulfilling its obligation to respond to data subjects' requests to exercise their rights.
- Where applicable, the subcontractor shall appoint a Data Protection Officer (hereinafter DPO) and shall notify its identity to the data controller in writing at the address indicated in Article six.
- Once the service is rendered, the Subcontractor agrees to return the personal data to the data controller and, where applicable and required, any software or hardware on which they are stored.
- This restitution must include the complete erasure of data existing on the equipment used by the Subcontractor. However, the Subcontractor may retain a copy, with the data duly blocked, while any liability relating to the provision of the services may arise.
Obligations of the data controller
The data controller must:
- Apply appropriate technical and organizational measures to ensure and demonstrate that the processing complies with the GDPR.
- Assume legal control over the proper obtaining of the various user consents, in accordance with the GDPR stipulations.
- Assume legal control over compliance with the information obligation under Articles 13 and 14 of the GDPR.
- Ensure GDPR compliance before and during processing.
- Ensure that the Subcontractor complies with the obligations set out in the GDPR before and during processing, in particular the provisions of Article 25 of said Regulation.
- Ensure that the processing and its purposes comply with the GDPR and the LOPD-GDD.
- Provide the Subcontractor with the necessary instructions to perform the service.
- Respect the principle of restricting the personal data necessary for the purposes of processing. Therefore, the data controller undertakes to render the data anonymous or to apply pseudonymisation to the extent possible and to always provide the Subcontractor only with the personal data strictly necessary for the provision of the service.
- Carry out prior consultations with the relevant supervisory authority.
- Respond to requests and inquiries from the Subcontractor.
- Appoint a DPO if necessary and notify the Subcontractor of its identity and contact details.