Terms of service

Every business grows a little differently. That's why we've built our pricing to be flexible. Each month pay only for subscribers you use. No more, no less.

These terms and conditions (“Terms”) establish the agreement (“Agreement”) between Bulletin and the entity or person requesting to use and accessing the Service (as defined below).

Bulletin provides a “software as a service” platform for providing and managing a communication "bot" to manage conversations between Customers and their recipients/End-Users, via the channels indicated on our website (and chosen by our Customer), being for the moment Facebook and Telegram.

Please review these Terms carefully. By accepting them, you confirm you have read, understood and accepted the Agreement for yourself or the entity you represent.


“Bulletin ” (also the “Company” or “we”) is Chatbots S.L., domiciled at Carrer Sardenya 229 4rt floor in Barcelona and with CIF/VAT: B-66996984 and Email: info@bulletin.chat

"You" means the person or entity whom you represent, creating an account with us and using the Bulletin Services under these Terms, for yourself or on behalf of your Customer (if different).

1. Definitions

The following terms shall have the meanings specified below:

  • "Authorised User" means any person who is employed by Customer to operate the Service.
  • "Confidential Information" means all information, whether written or oral, provided by the disclosing party to the receiving party and which (i) is known by the receiving party to be confidential; (ii) is marked as or stated to be confidential; or (iii) ought reasonably to be considered by the receiving party to be confidential.
  • "Customer" entity for whom the Service is provided, being You or the entity to whom the Service has been provided (see clause 2.2 below).
  • "End-user" means any person who uses Bulletin Services in purpose to communicate with the Customer.
  • "Services"
  • means the services and products supplied by Bulletin to the Customer under these Terms, described above and more specifically described at www.bulletin.chat, and any new service and functionality added to such Service by us.
  • "Visitor" means any person who is browsing any website where Bulletin Services are installed.
  • "User Guide" is the document setting out the scope of the Services and how to use them, available at support.bulletin.chat.

2. Agreement

  1. Bulletin agrees to provide You the Services via www.bulletin.chat or via mobile applications.
  2. In the event You are an agency or reseller contracting on behalf of a third party Customer, you warrant that you have authority to contract on their behalf, and the Services are provided to the Customer, and You are responsible for ensuring that the Customer complies with the terms of this Agreement applicable to it. In this case, all obligations of “you” hereunder, other than payment, are obligations of the Customer, and You must enter into an agreement with your Customer containing these terms or pass on these terms to them.
  3. By indicating your acceptance through signing these Terms or accepting the online form at www.bulletin.chat, by accessing or using the Service, You agree to be bound by all these Terms (including our Acceptable Use Policy) and other notices contained or referenced in this Agreement.
  4. We may modify the provisions of these Terms from time to time, and we shall provide you notice of such change, which shall come into effect on the date indicated in the notice. Modification shall not adversely affect the main provisions of the Agreement such as terms of payment or termination of Services. If you do not accept the new Terms, you may terminate the Agreement by written notice to us with no penalty.
  5. Further use of Services after additional modifications in the Terms have been implemented, shall constitute the consent to accept these modifications. I you reject the modifications, you may no longer use the Services.

3. Service description and subscription

  1. The Services are described at www.bulletin.chat and in our user documentation. We may add further functionality to the Services and we shall indicate if these additional services incur further fees or not.
  2. We decide on functionality, the use, subject matter and the range of particular Services as well as to cease rendering the Services. We shall not substantially modify the Services without notice of modifications to you (as indicated above).
  3. On subscribing for these Services, Bulletin.chat grants you a limited non-exclusive license to access and use the Service in accordance with these Terms. The duration of the license is set out in your pricing plan online or otherwise agreed in a Purchase Order, and may be terminated a set out below.
  4. Support on the Service is provided by email contact to help@bulletin.chat We strive to provide the service 24/7 with 99.5 % service availability on a monthly basis. All support tickets will be dealt with according to service priority, during office hours in Barcelona. We will give you notice of scheduled maintenance to your designated contact.

4. Access to the Services

  1. Access to our services is through www.bulletin.chat or our mobile application, once your application has been processed and confirmation of creation of your account.
  2. Customer and Authorised Users must be at least 18 years of age.
  3. Every Customer and Authorised User is assigned a particular password and login which must not be used by third parties without the Customer's consent. The Customer is responsible for keeping and proper protection of his password and login. Please notify us immediately if the protection is compromised.
  4. We reserve the right to access Customer accounts for legal, technical and administrative purposes and for security reasons. The information we may obtain in such a manner shall not be processed or made available to any third parties unless required by law, or court or administrative order, or necessary to defend our legitimate interests.

5. Use of the Services

  1. Our Services are exclusively designated for business use and must be used only in accordance with their purpose, application and these Terms.
  2. Our Services may only be used in accordance with their original purpose and these Terms. Detailed guidelines concerning proper use of the Services are set out in the User Guide and our Acceptable Use Policy in the Annex below.
  3. You undertake to use the Services in accordance with these Terms and the provisions of currently applicable law, and in full respect of third party rights.
  4. You may only use these Services for your own business purposes, and not for providing a service to any third party without our prior consent. Unauthorised lending, sale, granting of further licenses and sublicenses to the Services by the Customer or any other entity or person without express consent of Bulletin.Chat is prohibited.
  5. The Customer bears full responsibility for all contents, phrases and entries added to the network in connection with the use of offered Services. Customer must provide the Chatbot narratives, and the link to its privacy policy applicable to the processing of recipient personal data through use of the Services.
  6. Customer represents that it understands technical requirements necessary to use the Services and has no objections in respect thereof. The Customer is aware of risk and threats connected with electronic data transmission. Services are hosted on Amazon Web Services with servers located in Ireland.
  7. You may not modify or change the purpose and use of offered Services and products. Misleading others as to the existence of cooperation, association, relationship or acting on behalf of Bulletin.Chat is prohibited.
  8. As a condition of using the Services the Customer shall (a) as required by applicable law, provide notice to its customers (End-users) and obtain or have obtained consent if required for use of Bulletin.Chat Services as well as for processing of Authorised Users and End-users personal data by Bulletin.Chat and any of its third party service providers (including but not limited to the consent for processing a sensitive data if required); (b) be responsible for its employees, representatives, End-users, and Authorised Users that have access and use the Services; (c) ensure that they comply with any limitations or restrictions set forth in these Terms.
  9. If you violate any of these Terms (including our Acceptable Use Policy), applicable laws or generally accepted norms and conduct, this Agreement shall be automatically terminated.

6. Intellectual Property Rights (trademarks and copyrights), Customer Content

  1. "Bulletin.chat" is a trademark of the Company and is therefore subject to legal protection.
  2. The graphic design, materials, contents and website layout of the Service and the software behind the Service, or otherwise made available to You through the aforementioned website and Service are property of Bulletin.chat and protected by law.
  3. Customer represents that it holds all sufficient rights in any texts, images, and other content and materials it uploads to the Service, and that the same shall not infringe any third party rights or applicable law. Your content must comply with our Acceptable Use Policy below.
  4. You must obtain our prior written consent for any not permitted business and non-business use of our Services, in particular when disseminating and publicising particular elements (e.g. photos, films, texts) in other Internet services/websites, printed publications, books, multimedia presentations and in other electronic media as well as for the disposal or use of its work (adaptations, alterations, modifications).
  5. All information, data, text, software, graphics, commentary, video, messages, or any other materials submitted by using the Service, (collectively, "Data"), is the sole responsibility of the person from whom such Data originated. Customer is wholly responsible for all download, uploaded or otherwise transmitted via any of the Services. Bulletin.Chat is not responsible for the Data that the Customer submits in a Services.

7. Payment

  1. The use of offered Services is free of charge for the first 15 days (trial period). After signing up you get a new, fully functional Service account according to the selected plan. The free trial is to enable you to test the Service for your business and get to know our product before you make your decision about confirming subscription. During your trial period, the credit card is not required (or if entered, not charged).
  2. The subscriber capacity has +/-99 subscriber tolerance without charge if the subscriber capacity selected is below 4999 or 4999, and +/-999 subscriber tolerance without charge if the subscriber capacity selected is 5000 or above. If you exceed the subscriber capacity of your selected plan, we will automatically update capacity and prorated for the current month. If you have fewer subscribers than the selected subscriber capacity, this capacity will be updated on next billing cycle. Each month we charge the maximum number of subscribers from the last 30 days. Switching between plans can be done at any time in the billing cycle. If you want to upgrade your plan, it will be prorated for the rest of the billing cycle. In case you wish to downgrade your plan it will be updated on next month as each month we charge for the maximum number of subscribers from the last 30 days.
  3. Unless otherwise agreed, all payments shall be made by credit card through our contracted payment gateway on the website (Stripe) and you must provide complete and accurate credit card details. You will be charged the same day of the month you signed-up.
  4. Unless we are in breach of these Terms, we provide no refunds or credits for unused time of the Services or plan downgrades if you decide to close your account before the end of your subscription period.
  5. Failure to pay (or rejection of payment of the card) entails termination of the Service.
  6. The receipts for all payments will be provided electronically and stored in the product as PDF files.
  7. We may change our price list at any time and shall give you 30-day prior notice of change.

8. Termination and closing your account

  1. You can terminate the Agreement and cancel your account at any time in the panel under Subscription tab or by notice to us at info@bulletin.chat After canceling, your license and account will stop working after the current billing cycle. Credit from previous payments, if any, will be lost and is not refundable.
  2. We may suspend and/or terminate your account if you breach these terms, including through any illegal use of the Service. Breach will lead to immediate suspension of Services, and if you do not remedy the breach within 5 days of notice, we may terminate the account and this Agreement with no indemnity or penalty to you.
  3. We may terminate your account at any time providing you at least 2 months prior written notice.
  4. We shall not be liable for any damage suffered by the Customer or the End-user arisen due to the suspension or closing the account, unless caused by our breach of these Terms.

9. Guarantee and limited liability

  1. We strive to provide the Services professionally and diligently in accordance with industry practice, to ensure accessibility and continuity of the Services in accordance with their use and purpose and these Terms. Any default in the Service must be notified to us promptly, and we will use all reasonable efforts to remedy the default in the shortest time possible.
  2. Except as otherwise provided by mandatorily applicable law, our Services included on or otherwise made available to the Customer through the aforementioned website are provided by "as is" and "as available" basis, unless specified otherwise in the Agreement. You have tested the Service and accept its fitness for your purposes (which have not be stated to us).
  3. Bulletin.Chat does not guarantee compatibility of our Services and products with other producers' software or services. The Customer shall bear responsibility for the choice and consequences following from the use of other technologies. Please be aware that due to the complexity of long-distance data transmission there is no possibility to ensure an absolute security, accessibility and continuity of the provided Service.
  4. Bulletin.Chat stipulates that the Customer content and any opinions or materials provided by users of the Service do not reflect in any possible manner Company's views and opinions. Bulletin.Chat does not monitor or control Customer's content or opinions on a continual basis; if, however, any content or opinions in breach with these Terms should be notified to us and we shall take all reasonable measures, in accordance with applicable law, to remove them as soon as possible.
  5. You agree that Bulletin.Chat shall bear no liability in particular for:
    1. all negative consequences being the result of force majeure,
    2. phrases and entries added by Customers (Customer content) and third parties to the network in connection with the use of offered Services,
    3. usage of the Service that is unlawful or inconsistent with these Terms,
    4. any of Customer's other operations while using the Services,
    5. lack of accessibility of Services not caused by Bulletin.Chat,
    6. damage suffered by the Customer, End-user or any other person or entity arisen due to the suspension or closing the account by the Customer or for other reasons arising from the Customer's fault,
    7. damage suffered by the Customer as a result of a third party accessing the Services using the Customer credentials (unless such access is due to our negligence or wilful misconduct),
    8. damage to the Customer arising from the impossibility to use the Services including damage actually suffered, the loss of expected benefits, data loss, damage or computer crash, the costs of substitute equipment and software, shut-down, company reputation infringement, or
    9. consequences of failure to perform or improper performance of obligations undertaken by other users even though such an obligation has been undertaken using offered products and Services.

In no event, except as required by mandatorily applicable law, will Bulletin.chat be liable for indirect damages of any type. For direct damages, our maximum liability is the amount received from Customer as fees hereunder during the previous 12 months.

10. Privacy and processing of personal data

  1. Bulletin.Chat is dedicated to protecting data protection and to promote compliance with privacy rules applicable in the European Union.
  2. All data of a personal data processed in performance of this Agreement is regulated by our Privacy Policy, which is part of these Terms and which includes our Data Processor Agreement covering our processing of data under your responsibility, and which is set out in Annex 1.
  3. Any observation or breach of data protection may be reported to us on email info@bulletin.chat

11. Other provisions

  1. We reserve the right to update these Terms and our Privacy Policy at any time and we shall provide you 30 days' prior written notice, via email. If you do not accept the new terms, you may cancel your account at any time.
  2. All disputes arising in connection with these Terms and Conditions shall be primarily resolved amicably. Failing a good faith attempt at amicable resolution, all and any dispute shall be submitted to the exclusive jurisdiction of the courts of Barcelona, Spain. Notwithstanding the foregoing, and as an exception, Bulletin.chat may initiate actions in the courts with jurisdiction in the domicile of the Customer for any claim for payment.
  3. These Terms and the relationship between Bulletin.chat and You are governed by Spanish law.

Acceptable Use Policy

  1. This Acceptable Use Policy applies to Bulletin.Chat Services accessible through www.bulletin.chat and our mobile application.
  2. To ensure proper and fluent functioning of the system, all Bulletin.Chat Customers agree not to misuse the Service in any manner, or use it in breach of our Terms including our Privacy Policy.
  3. Consequently, by way of illustration, the Customers agree not to:
    1. hinder or prevent functioning of the Service, particularly through any form of reverse engineering or hacking the Service, attempting to gain unauthorized access to the Service (or any portion thereof) or related systems, networks or data;
    2. use the Services in a way contradictory to this Terms and causing a real danger for the Bulletin.Chat and its other Customers, for example use the Service to generate or send unsolicited communications or communication judged to be a spam, or otherwise cause Bulletin.Chat to become impaired in its ability to send communications on its own or on its Customers';
    3. misrepresent or mask the origin of any data, content or other information you submit for example by "spoofing", "phishing", manipulating headers or other identifiers, impersonating anyone else or access the Service via another Customer's account without their permission;
    4. use the Services in a way which violates the rights of other individuals or laws;
    5. promote or advertise products or services different from those belonging to the Customer, without legal basis;
    6. use the Services to provide, or incorporate the Services into, any product or service provided to a third party without explicit agreement regulating such situation established with Bulletin.Chat; or
    7. allow or encourage anyone else to commit any of the actions listed above.

Annex 1 -Data Protection

This Annex regulates the processing of any personal data by Bulletin.Chat ("the Company", or "we/us") during the course of provision of our Services (as set out in the Bulletin.Chat Terms of Service above) and is effective as of the date of opening a Customer Account. All agreements between the Parties hereto are collectively referred to herein as "the Agreement."

With respect to provisions regarding processing of Personal Data, in the event of a conflict between the Agreement and this Privacy Annex, the provisions of this Annex shall prevail.


1. Definitions

For the purpose of this Annex, the following terms shall take the meaning set out herein:

  • Personal Data: all information about an identified or identifiable individual; An identifiable natural person shall mean any person whose identity can be determined, directly or indirectly, in particular by means of an identifier, such as a name, an identification number, location data, an online identifier or one or more identity elements Physical, physiological, genetic, psychological, economic, cultural or social.
  • Data Processor: the natural or legal person, public authority or other organization processing Personal Data on behalf of the Data Controller.
  • Data Subject: is the individual that is identified or identifiable.
  • Data Controller: the natural or legal person, public authority, or other organization that, alone or jointly with others, defines the purposes and means of the processing.
  • Processing: Any operation or set of operations carried out on Personal Data or Personal Data sets, whether by automated processes or not, such as collection, registration, organization, structuring, preservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of access, collation or interconnection, limitation, suppression or destruction.
  • Security breach of the Personal Data: any breach of security that results in the destruction, loss or accidental or unlawful alteration of Personal Data transmitted, preserved or otherwise processed, or unauthorized communication or access to such data.
  • Services: Bulletin.chat Services

2. Object, Term and Scope

This Annex regulates the processing of personal data by Bulletin under the Agreement for and on behalf of Customer, with respect to data under the responsibility of Customer. The duration of such processing shall be for the period during which the Parties perform their applicable obligations under the Agreement. The purposes, the type of personal data and categories of data subjects are as described below and in additional addenda in the case of extending any personal data processing.

3. Data Protection Laws Compliance

Each Party shall comply with all applicable laws relating to privacy and data protection, including the EU General Data Protection Regulation (2016/679) on and from 25 May 2018, the EU Privacy and Electronic Communications Directive (2002/58/EC) as implemented in each jurisdiction, and any amending or replacement legislation from time to time (collectively and individually, "Data Protection Laws").

I. Bulletin as Data Controller

4. Data and purpose of processing

In accordance with Data Protection Laws, the processing the Personal Data of the individuals mentioned in the Agreement, being identification data (name, surname, position, email address and telephone) of both the Customer's signatory and its technical or commercial contact persons and Authorised Users, is necessary for the execution of the Agreement and for the invoicing of the contracted services, and more generally to manage our contractual and commercial relationship with the Customer and its Customers, and to inform them promptly about any aspect related to the services provided or that can be performed by the Company in the future. Including

  • to provide, maintain and facilitate the Services as well as to ensure safe and guaranteed Service performance, upgrade and improve the functionality of the Services,
  • to provide Customer with access to its Personal Data and maintain this access for the duration of paid usage of Services (active subscription) as well as after the subscription is expired (inactive subscription), until the Service is fully terminated by a written request (in accordance with the Agreement),
  • to secure (establish, investigate or defend) Customer's, as well as Company's claims that may arise due to the Services,
  • to stay connected with the Customer to present up-to-date offer of Services and instructions or tips related to the Service.

We also collect other information provided by Customer while using our Services. Some of the provided Customers information such as: your IP address, domain, browser type, operating system type etc. may be automatically acquired when a user visits our websites.

Such Personal Data will not be shared with any third party, however they may be processed within our third party service provider platforms, currently Amazon Web Services Ireland, under contract clauses that provide adequate safeguards for data processing.

Although the consent of the aforementioned persons is not necessary for this processing, Customer agrees to inform them of the possibility of exercising their rights of access, rectification, cancellation and opposition, limitation and restriction of treatment in the terms established by the current legislation, by writing to the following address: privacy@bulletin.chat. They may, if they so wish, also file a complaint, if any, with the Spanish Agency for Data Protection.

Customer declares that the data of the aforementioned persons are correct and updated, and undertakes to communicate the provisions of this clause to the aforementioned persons. The Customer agrees and warrants that the processing, including the transfer of its Personal Data has been and will continue to be carried out in accordance with the relevant provisions of the applicable Data Protection Laws (and, where applicable, has been notified to the relevant authorities of the Member State where the Company is established or has its representative) and does not violate the relevant provisions of that State.

Retention of Copies. The Company may retain this Personal Data to the extent required by applicable European Union law or the law of an EU Member State and only to the extent and for such period as required by such laws and always provided that the Company shall ensure the confidentiality of all such Customer Personal Data and shall ensure that such Personal Data is only processed as necessary for the purpose(s) specified in such law requiring its storage and for no other purpose.

The Customer agrees that after the termination or expiration of the Agreement its data may be stored as a backup for the time needed to secure (establish, investigate or defend) Customer's and Company's claims that may arise due to the performance of the Services (for the time it takes for the claims to be barred).

II. Bulletin as Data Processor, for and on behalf of Customer

5. Appointment as Data Processor for and on behalf of Customer

During the provision of its services under the Agreement, Bulletin.Chat may access certain personal data under the responsibility of the Customer, in particular (but without limitation), the data set out below ("End User Personal Data") relating to the indicated persons ("Data Subjects"). Under applicable privacy regulations, the Customer is responsible for its data and is what is known under privacy regulation as the Data Controller. The Customer appoints Bulletin.Chat as a Data Processor, to process End User Personal Data on Customer's behalf, for the purpose of providing the Service.

6. Rights and responsibilities of the Customer as Data Controller

As established in the GDPR, the Customer as Data Controller shall:

  1. Implement appropriate technical and organizational measures to ensure and be able to demonstrate that the processing is carried out in accordance with applicable legislation.
  2. Adopt data protection policies.
  3. Ensure that the Data Protection Officer or, in his / her absence, the Privacy Officer is involved in an adequate and timely manner in all matters relating to the protection of End User Personal Data.
  4. Adhere to a code of conduct that can be approved by the Commission or other competent authority.
  5. Keep a record of processing activities in the case of processing End User Personal Data that may pose a risk to the rights and freedoms of the data subject and / or in a non-occasional manner, or which involves the processing of special categories of data and / or data relating to convictions and infractions.
  6. Make available to the interested parties the essential aspects of this agreement, at the request of the Data Processor.

7. Rights and responsibilities of Bulletin as Data Processor

As established in the GDPR, Bulletin.Chat, as Data Processor, shall:

  1. Process End User Personal Data only on the basis of documented instructions from the Data Controller, including transfers of End User Personal Data to a third country or international organization, unless otherwise required to do so under Union law or applicable Member State law; in such case, the Data Processor will inform the Data Controller of that legal requirement prior to the processing, unless otherwise prohibited by such law or in the public interest.
  2. Ensure that the persons authorised to process End User Personal Data have undertaken to respect confidentiality or are subject to an obligation of confidentiality of a statutory nature.
  3. Take all appropriate technical and organisational measures to ensure a level of safety appropriate to the risk of processing.
  4. Respect the conditions for having recourse to another Data Processor, as established in the current legislation on protection of End User Personal Data.
  5. Assist the Data Controller, taking into account the nature of the processing, through appropriate technical and organisational measures, whenever possible, so that it can comply with its obligation to respond to requests for the exercise of the rights of the data subjects.
  6. Assist the Data Controller in ensuring that they comply with their obligations, taking into account the nature of the processing and the information that is available to the Data Processor.
  7. At the choice of the Data Controller, either destroy or return all End User Personal Data once the processing services have been completed, and destroy any existing copies unless the retention of End User Personal Data is required under Union or applicable Member State law.
  8. Make available to the Data Controller all information necessary to demonstrate compliance with the obligations established in herein, as well as to allow and contribute to the performance of audits, including inspections, by the controller or other authorised auditors for the Data Controller.
  9. Process the End User Personal Data placed at the disposal of the Data Processor in a way that ensures that the personnel in charge follow the instructions of the Data Controller.
  10. Ensure that the Data Protection Officer or, in his / her absence, the Privacy Officer is involved in an adequate and timely manner in all matters relating to the protection of End User Personal Data.
  11. Adhere to a Code of Conduct that is approved by the Commission or other competent authority.
  12. Keep a record of processing activities in the case of processing End User Personal Data that may pose a risk to the rights and freedoms of the data subject and / or in a non-occasional manner, or which involves the processing of special categories of data and / or data relating to convictions and infractions.

8. Data subjects' exercise of their rights

If a Data Subject addresses a request or exercises any of the rights established in the General Data Protection Regulation, the Controller and / or the Processor must provide the information requested and perform any required actions, without delay and, at the latest, within one month from receiving the request, which may be extended for a further two months if necessary, taking into account the complexity of the application and the number of applications.

Similarly, but in the event that the Data Controller and / or the Processor do/es not proceed with the request of the Data Subject, he/she shall inform the latter without delay, and no later than one month after receipt of the request, shall provide the Data Subject with the reasons why he/she/they has/ve not acted and inform the Data Subject of his right to file a complaint before a competent authority and to file a judicial appeal. The response to the Data Subject's request shall be made in the same format as that used by the person concerned, unless he/she requests that it be done otherwise.

9. Subcontracting

As Data Processor, Bulletin.Chat may provide access to a subcontractor processor to End User Personal Data if we reasonably consider such access and processing necessary to the performance of the Services. In the event of such access and before the access takes place, the Company shall ensure that an agreement with the third party is in place which is sufficient to require it to treat personal data in accordance with the applicable provisions of this Agreement and applicable. The Customer authorises Bulletin.Chat to subcontract such processing in its name, with prior notification to Customer. The Customer expressly authorises the subcontracting of the services indicated above (AWS Ireland) for the processing of any personal data by Bulletin.Chat on behalf of the Customer within the scope of the Services.

10. International transfer of data

International transfers of End User Personal Data may only be performed if the requirements of Data Protection Laws and regulations that regulate them, are met. Customer acknowledges that in the course of subcontracting indicated above, the Customer systems and data may be hosted by Company outside the EEA or territories with adequate safeguards approved by the European Commission (as set out in the corresponding Service Description, including details of third party service providers), and authorises such international transfers unless expressly prohibited or otherwise indicated on a SoW or Order Form. In the event of subcontractors outside the EEA, the Company guarantees the data is shared under agreements that provide adequate safeguards as provided by law. If a party carries out an international transfer of data without the other party's consent, the latter shall be exempted from any liability that may arise as a result of or in connection with such transfer.

11. Security breach of the End User Personal Data

Insofar as there exists an instruction from a competent supervisory authority, a development of a national legislation or a delegated act, in the event of a security breach of the End User Personal Data, the Data Controller and/or Data Processor shall notify the competent supervisory authority of such breach without undue delay, and if possible, no later than 48 hours after it happened.

12. Termination, resolution and expiration

In the event of termination, resolution or expiration of the Agreement, the Data Processor shall not keep the End User Personal Data unless otherwise legally required to do so. Otherwise, upon termination, resolution or expiration, or when no longer legally required to keep the data, the Data Processor shall destroy or return to the Data Controller all End User Personal Data and any copies of it, as well as any support or other document containing any End User Personal Data.

Exhibit 1 - Scope of Processing

In accordance with the provisions set out in herein and in the GDPR, the Data Processor shall process the category of Data Subjects and type of End User Personal Data instructed by the Data Controller set out hereunder:

Category of Data SubjectType of Data
Customer authorised users of Customer IT systemsIdentification, Professional contact, IP address
Customer's clients and other end-users connecting with the ServiceIdentification, personal or professional contact data, socio-economic, financial, behavioural, (as per narratives created by the Customer)

Nature of Processing:

  • collection, recording, organisation, structuring, storage,
  • adaptation or alteration, alignment or combination,
  • retrieval, consultation,
  • disclosure by transmission, dissemination or otherwise making available,
  • restriction,
  • erasure or destruction

Purpose of Processing

Provision of Bulletin.Chat Services under the Agreement.