utm.coupons

Data Processing Agreement

For customers who are controllers, this describes our responsibilities as a processor.

Effective September 2026

Roles

When you use utm.coupons to run promotions, you are the data controller and we are the data processor for the personal data of your customers.

What we process

  • Share identifiers and referral metadata
  • Verified order events tied to a code
  • Support communications

Sub-processors

We use a small set of vetted sub-processors for hosting, email and analytics. A current list is available on request.

Security

  • Encryption in transit and at rest
  • Role-based access controls
  • Regular penetration testing
  • SOC 2 Type II controls

Breach notification

We will notify affected controllers without undue delay after becoming aware of a personal data breach.

International transfers

Where data is transferred outside its origin region, we rely on Standard Contractual Clauses or equivalent safeguards.

Deletion

On termination we delete or return personal data within 30 days, except where we must retain it to comply with law.