Data processing agreement
Last updated 20 October 2026
This data processing agreement ("DPA") forms part of the terms of service for any customer ("Customer") who uses Maps by DeltaBreen in the course of a business on a site or application used by other people, and applies automatically from the moment the Customer does so. It is written to meet Article 28 of the GDPR. DeltaBreen Limited (the operator of Maps by DeltaBreen), a company registered in Ireland with company number 826627 and VAT number IE4835019QH, of Gorey, Co. Wexford, Ireland is the "Processor"; the Customer is the "Controller". Enterprise customers may sign a countersigned copy on request.
1. Subject matter, duration, nature and purpose
The Processor serves map tiles, fonts, sprites, styles, static map images, search, elevation and directions answers to the Controller's end users, and hosts the data layers and icons the Controller uploads. Processing consists of receiving token, tile, raster tile, static image, search, elevation and directions (route, distance table and travel-time area) requests from end users' browsers and apps, answering them, storing and serving the Controller's uploads, keeping counts of what end users do with the Controller's maps on plans with visitor stats, and holding the associated account, key, usage and audit records. Duration: the term of the Controller's account plus the retention periods in the privacy policy.
2. Data and data subjects
End-user data: IP addresses and user agents in transient request logs (at most 30 days), the origin of the page, the tile coordinates requested, and the text and position sent with a search or elevation request and the points of a directions request, including an end user's location when they choose to share it, none of which is stored; on plans with visitor stats, counts per map and day of views, places opened, buttons pressed and the towns picked in a search, which hold no address, typed text, IP address or cookie. Uploaded data: whatever the Controller puts in the data layers and icons it uploads. Account data: email addresses of the Controller's users, key names and origins, usage counts, style content, hashed IP addresses in the audit log. Data subjects: the Controller's staff and the end users of the Controller's site or application.
3. The Processor's obligations
- Process personal data only on the Controller's documented instructions, which are these terms and the use of the service, unless required by EU or Member State law, in which case the Processor informs the Controller first where allowed.
- Ensure everyone with access is bound by confidentiality.
- Apply the security measures in section 5.
- Engage sub-processors only as listed in section 6, under written terms no less protective than this DPA, and give 30 days' notice by email of a change so the Controller may object; if the Controller reasonably objects on data-protection grounds and we cannot resolve it, the Controller's sole remedy is to stop using the affected feature or terminate the affected service.
- Assist the Controller with data subject requests, security, breach notification and impact assessments, given the nature of the processing and the information available.
- At the Controller's choice, delete or return all personal data at the end of the service and delete existing copies, unless EU or Member State law requires storage; account deletion does this within 30 days.
- Make available the information needed to show compliance and allow audits, on reasonable notice, no more than once a year unless an authority requires otherwise, under confidentiality, at the Controller's cost, and without access to other customers' data or to our security secrets — a recognised third-party audit report satisfies this where one exists.
4. The Controller's obligations
The Controller warrants that it has a lawful basis for its end users' data reaching the Processor, that its privacy notice mentions the map provider, and that it configures keys and origins so only its own sites use them.
5. Security measures
- Transport encryption (TLS) on every connection; the token of every tile request that carries one (vector tiles and the raster tiles of our map plugins) is validated before a tile is served, by a web application firewall in front of the tile host or, where tiles are served straight from the Processor's tile server, by that server; and the Processor's servers check the key of every static image and key-based raster tile request.
- Secret keys stored as hashes; server secrets kept outside the database; production reachable only over a private network.
- No cookies or tracking on the tile host; no storage of tile requests; request logs retained at most 30 days.
- Administrative actions logged; per-tenant audit log; encrypted backups within the EU.
6. Sub-processors and international transfers
The Controller authorises the sub-processors below. Where a sub-processor processes personal data outside the EEA, the transfer relies on an adequacy decision, the EU–US Data Privacy Framework, or Standard Contractual Clauses with appropriate safeguards, as noted for each.
| Sub-processor | Purpose | Location | Transfer mechanism |
|---|---|---|---|
| Cloudflare, Inc. | Edge network, cache, DNS, TLS and web application firewall in front of the tile host and the app; the bot check on the sign-in form (Turnstile); storage (R2) for uploaded data layers and icons and for landmark photos | Global edge | EU–US Data Privacy Framework and Standard Contractual Clauses |
| Paddle.com Market Ltd | Merchant of record for paid plans: checkout, invoices, VAT, refunds | UK / EU | UK adequacy decision |
| Hetzner Online GmbH | Servers running the API, the database and the map renderer, and the entry point of the tile host | EU (Germany / Finland) | None needed |
| Contabo GmbH | Server running the tile host: map tiles, fonts and icons | Germany (EU) | None needed |
| OVH SAS (OVHcloud Object Storage) | Storage for files attached to support messages | Germany (EU) | None needed |
| BunnyWay d.o.o. (bunny.net) | Edge network and cache in front of the tile host for map tiles, fonts and icons, where we choose to use it. Not in use at present | Slovenia (EU); edge locations worldwide | Not in use at present; the mechanism for its edge locations outside the EEA is stated here before it is used |
| Scaleway SAS (Transactional Email) | Transactional email: sign-in codes, workspace invitations, support replies and usage notices | France (EU) | None needed |
| Slack Technologies, LLC | Notices to our own team: new accounts, support tickets and usage warnings, with email addresses shortened to their first letter and domain | United States | EU–US Data Privacy Framework and Standard Contractual Clauses |
Contabo GmbH and BunnyWay d.o.o. were added on 13 October 2026. BunnyWay d.o.o. handles no data until we put it to use.
7. Breach notification
The Processor notifies the Controller without undue delay, and in any case within 48 hours, of becoming aware of a personal data breach affecting the Controller's data, with the information Article 33(3) requires as it becomes available.
8. Liability and law
Liability under this DPA is subject to the limits in the terms of service. It is governed by Irish law. Questions: [email protected].