Data processing agreement

Last updated on October 30, 2026

Microlink acts as a processor of the data you send through the API. This DPA sets out how we handle it.

At a glance

Who signs: Microlink Labs, S.L. (Spain, EU).
Role: Microlink is the processor. You, the customer, are the controller.
What we process: The URLs and request parameters you send, the publicly accessible pages we fetch, and the outputs we return (screenshots, PDFs, metadata). We only fetch publicly accessible pages: we don’t log in or bypass access controls. For the dashboard, your account data (email).
Retention: Cached responses: 24 hours by default, configurable with ttl up to 31 days. Operational logs: 15 days. Deletion within 15 days of termination.
International transfers: EU Standard Contractual Clauses (Commission Decision 2021/914), the UK International Data Transfer Addendum and the Swiss FADP amendments are available.
Subprocessors: The current list is at microlink.io/subprocessors.

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Processor: Microlink Labs, S.L., with tax ID (CIF) B93825263 (EU VAT number ESB93825263), registered address at Paseo Fotógrafo Verdú, 2, Piso 4, Puerta IZ, 30002 Murcia, Spain, and registered in the Mercantile Registry of Murcia, sheet MU-121050 (“Microlink” or “Processor”). Contact for data protection matters: [email protected].

This Data Processing Agreement (“Agreement”) forms part of the Contract for Services under the Microlink Terms and Conditions (the “Principal Agreement”).

This Agreement is an amendment to the Principal Agreement and is effective upon its incorporation in the Principal Agreement, which incorporation may be specified in the Principal Agreement or an executed amendment to the Principal Agreement.

Upon its incorporation into the Principal Agreement, this Agreement will form a part of the Principal Agreement.

The term of this Agreement shall follow the term of the Principal Agreement. Terms not defined herein shall have the meaning as set forth in the Principal Agreement.

WHEREAS

(A) The Company acts as a Data Controller.

(B) The Company wishes to subcontract certain Services, which imply the processing of personal data, to the Data Processor.

(C) The Parties seek to implement a data processing agreement that complies with the requirements of the current legal framework in relation to data processing and with the 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, and repealing Directive 95/46/EC (General Data Protection Regulation).

(D) The Parties wish to lay down their rights and obligations.

IT IS AGREED AS FOLLOWS:

1. Definitions and Interpretation

1.1 Unless otherwise defined herein, capitalized terms and expressions used in this Agreement shall have the following meaning:

1.1.1 “Agreement” means this Data Processing Agreement and all Schedules;

1.1.2 “Company Personal Data” means any Personal Data Processed by a Contracted Processor on behalf of Company pursuant to or in connection with the Principal Agreement;

1.1.3 “Contracted Processor” means a Subprocessor;

1.1.4 “Data Protection Laws” means EU Data Protection Laws and, to the extent applicable, the data protection or privacy laws of any other country;

1.1.5 “EEA” means the European Economic Area;

1.1.6 “EU Data Protection Laws” means EU Directive 95/46/EC, as transposed into domestic legislation of each Member State and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR;

1.1.7 “GDPR” means EU General Data Protection Regulation 2016/679;

1.1.8 “Data Transfer” means:

1.1.8.1 a transfer of Company Personal Data from the Company to a Contracted Processor; or

1.1.8.2 an onward transfer of Company Personal Data from a Contracted Processor to a Subcontracted Processor, or between two establishments of a Contracted Processor, in each case, where such transfer would be prohibited by Data Protection Laws (or by the terms of data transfer agreements put in place to address the data transfer restrictions of Data Protection Laws);

1.1.9 “Services” means the software services the Company provides.

1.1.10 “Subprocessor” means any person appointed by or on behalf of Processor to process Personal Data on behalf of the Company in connection with the Agreement.

1.2 The terms, “Commission”, “Controller”, “Data Subject”, “Member State”, “Personal Data”, “Personal Data Breach”, “Processing” and “Supervisory Authority” shall have the same meaning as in the GDPR, and their cognate terms shall be construed accordingly.

2. Processing of Company Personal Data

2.1 Processor shall:

2.1.1 comply with all applicable Data Protection Laws in the Processing of Company Personal Data; and

2.1.2 not Process Company Personal Data other than on the relevant Company’s documented instructions.

2.2 The Company instructs Processor to process Company Personal Data.

3. Processor Personnel

Processor shall take reasonable steps to ensure the reliability of any employee, agent or contractor of any Contracted Processor who may have access to the Company Personal Data, ensuring in each case that access is strictly limited to those individuals who need to know / access the relevant Company Personal Data, as strictly necessary for the purposes of the Principal Agreement, and to comply with Applicable Laws in the context of that individual’s duties to the Contracted Processor, ensuring that all such individuals are subject to confidentiality undertakings or professional or statutory obligations of confidentiality.

4. Security

4.1 Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Processor shall in relation to the Company Personal Data implement appropriate technical and organizational measures to ensure a level of security appropriate to that risk, including, as appropriate, the measures referred to in Article 32(1) of the GDPR.

4.2 In assessing the appropriate level of security, Processor shall take account in particular of the risks that are presented by Processing, in particular from a Personal Data Breach.

5. Subprocessing

5.1 Processor shall not appoint (or disclose any Company Personal Data to) any Subprocessor unless required or authorized by the Company.

5.2 For transparency, a current list of authorized Subprocessors is maintained and available at microlink.io/subprocessors. The Company will be notified of any changes to this list in accordance with applicable data protection requirements.

6. Data Subject Rights

6.1 Taking into account the nature of the Processing, Processor shall assist the Company by implementing appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of the Company obligations, as reasonably understood by Company, to respond to requests to exercise Data Subject rights under the Data Protection Laws.

6.2 Processor shall:

6.2.1 promptly notify Company if it receives a request from a Data Subject under any Data Protection Law in respect of Company Personal Data; and

6.2.2 ensure that it does not respond to that request except on the documented instructions of Company or as required by Applicable Laws to which the Processor is subject, in which case Processor shall to the extent permitted by Applicable Laws inform Company of that legal requirement before the Contracted Processor responds to the request.

7. Personal Data Breach

7.1 Processor shall notify Company without undue delay upon Processor becoming aware of a Personal Data Breach affecting Company Personal Data, providing Company with sufficient information to allow the Company to meet any obligations to report or inform Data Subjects of the Personal Data Breach under the Data Protection Laws.

7.2 Processor shall co-operate with the Company and take reasonable commercial steps as are directed by Company to assist in the investigation, mitigation and remediation of each such Personal Data Breach.

8. Data Protection Impact Assessment and Prior Consultation

8.1 Processor shall provide reasonable assistance to the Company with any data protection impact assessments, and prior consultations with Supervising Authorities or other competent data privacy authorities, which Company reasonably considers to be required by article 35 or 36 of the GDPR or equivalent provisions of any other Data Protection Law, in each case solely in relation to Processing of Company Personal Data by, and taking into account the nature of the Processing and information available to, the Contracted Processors.

9. Deletion or return of Company Personal Data

9.1 Subject to this section 9 Processor shall promptly and in any event within 15 days of the date of cessation of any Services involving the Processing of Company Personal Data (the “Cessation Date”), delete and procure the deletion of all copies of those Company Personal Data.

10. Audit rights

10.1 Subject to this section 10, Processor shall make available to the Company on request all information necessary to demonstrate compliance with this Agreement, and shall allow for and contribute to audits, including inspections, by the Company or an auditor mandated by the Company in relation to the Processing of the Company Personal Data by the Contracted Processors.

10.2 Information and audit rights of the Company only arise under section 10.1 to the extent that the Agreement does not otherwise give them information and audit rights meeting the relevant requirements of Data Protection Law.

11. Data Transfer

11.1 The Processor may not transfer or authorize the transfer of Data to countries outside the EU and/or the European Economic Area (EEA) without the prior written consent of the Company. If personal data processed under this Agreement is transferred from a country within the European Economic Area to a country outside the European Economic Area, the Parties shall ensure that the personal data are adequately protected. To achieve this, the Parties shall, unless agreed otherwise, rely on EU approved standard contractual clauses for the transfer of personal data.

11.2 Where required by Data Protection Laws, for transfers of Company Personal Data subject to the GDPR, the Parties rely on the standard contractual clauses approved by Commission Implementing Decision (EU) 2021/914 (the “EU SCCs”), as follows: Module 2 (controller to processor) or Module 3 (processor to processor), as applicable, for onward transfers by Processor to Subprocessors located outside the EEA; and Module 4 (processor to controller) where the Company, acting as controller, is located outside the EEA.

11.3 For transfers of Company Personal Data subject to the data protection laws of the United Kingdom, the Parties rely on the EU SCCs as supplemented by the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses issued by the UK Information Commissioner’s Office (the “UK Addendum”).

11.4 For transfers of Company Personal Data subject to the Swiss Federal Act on Data Protection (“FADP”), the Parties rely on the EU SCCs with the amendments required by the FADP.

12. General Terms

12.1 Confidentiality. Each Party must keep this Agreement and information it receives about the other Party and its business in connection with this Agreement (“Confidential Information”) confidential and must not use or disclose that Confidential Information without the prior written consent of the other Party except to the extent that:

disclosure is required by law; and
the relevant information is already in the public domain.

12.2 Notices. All notices and communications given under this Agreement must be in writing and will be delivered personally, sent by post or sent by email to the address or email address set out in the heading of this Agreement at such other address as notified from time to time by the Parties changing address.

13. Governing Law and Jurisdiction

13.1 This Agreement is governed by the laws of Spain.

13.2 Any dispute arising in connection with this Agreement, which the Parties will not be able to resolve amicably, will be disputed under the spanish jurisdiction.

IN WITNESS WHEREOF, this Agreement is entered into with effect from the date first set out below.

"Microlink"
Microlink Labs, S.L.
Name: José Francisco Verdú Gambín
Title: Sole Director
Date: on execution

Annex I: Description of the processing

Data exporter: the Company, acting as controller.

Data importer: Microlink Labs, S.L., acting as processor. Contact: [email protected].

Subject matter and nature of the processing: on the Company’s request, Processor fetches publicly accessible web pages and returns outputs generated from them (screenshots, PDFs, metadata) through the Microlink API. Processor only fetches publicly accessible pages and does not log in or bypass access controls.

Purpose of the processing: providing the Services under the Principal Agreement.

Categories of personal data: URLs and request parameters submitted by the Company; content of the publicly accessible pages fetched and the outputs generated from them (screenshots, PDFs, metadata, text); IP addresses and API keys recorded in operational logs; account contact details (email address).

Categories of data subjects: individuals whose personal data may be contained in the URLs, request parameters or publicly accessible web pages that the Company submits for processing; and the Company’s authorised users of the Microlink dashboard and API (account holders).

Sensitive data: none intended. The Company shall not submit special categories of personal data. Any such data that appears incidentally on a publicly accessible page submitted by the Company is processed only as part of generating the requested output and is subject to the same retention limits.

Frequency of the transfer: on each request the Company sends to the Services.

Retention: cached responses are kept for 24 hours by default, configurable by the Company with the ttl parameter up to 31 days; operational logs are kept for 15 days; Company Personal Data is deleted in accordance with Section 9.

Annex II: Technical and organisational measures

Encryption in transit: all traffic to the API, dashboard and log ingestion is encrypted with TLS; TLS 1.0 and 1.1 are rejected, minimum TLS 1.2.
Encryption at rest: stored outputs are encrypted with AES-256 (AWS S3 server-side encryption); compute volumes are encrypted (DigitalOcean); operational logs are encrypted with AES-256 (Datadog).
Access control (customers): API access is authenticated with an API key sent over HTTPS. Each key is bound to one account, which determines its plan, quota, rate limits and accessible data. Accounts are isolated from one another. The Company can rotate its keys on demand, and Microlink rotates keys if compromise is suspected.
Access control (personnel): administrative access to production systems and logs is restricted to Microlink’s two founders, using individual accounts, with no shared accounts and no third-party access.
Scope minimisation: the service only fetches publicly accessible web pages. It does not log in to websites or bypass access controls, and the API performs no write operations on customer systems.
Retention: cached outputs are kept for 24 hours by default, configurable by the Company via the ttl parameter up to a maximum of 31 days; operational logs are kept for 15 days; Company data is deleted within 15 days of termination.
Network protection: Cloudflare acts as the entry point for the service, providing CDN, DNS, web application firewall and TLS termination.
Incident response: Microlink maintains a documented Incident Response Plan covering detection, containment, eradication, recovery and notification, including notification to the Company without undue delay after becoming aware of a personal data breach.
Vulnerability and patch management: Microlink maintains a documented Vulnerability and Patch Management Policy with remediation targets based on severity.
Physical security: Microlink operates no physical infrastructure. Physical security is provided by its hosting subprocessors under their own certified security programmes.
Subprocessors: subprocessors are bound by written data protection terms and listed at microlink.io/subprocessors.

Annex III: Subprocessors

The Subprocessors authorised under Section 5 are listed at microlink.io/subprocessors.

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