Legal

Data Processing Agreement

Last updated: 18 September 2026

This is a draft template prepared for Vellym, UAB and has not yet been reviewed by legal counsel. Fields shown in brackets are placeholders — replace them with the real details before publishing this page. The sub-processor list in Section 5 must reflect your actual, current infrastructure providers before this document is relied on by a customer.

This Data Processing Agreement (“DPA”) forms part of the Terms of Service between Vellym, UAB (“Processor”, “we”) and the customer using the Service (“Controller”, “you”), and applies whenever we process personal data on your behalf as part of providing the Service. It reflects the requirements of Article 28 of the GDPR.

Where you use the Service to process personal data belonging to your own end users or customers (for example, names or likenesses appearing in brand assets you upload), you act as the data controller for that data, and we act as your data processor.

1. Subject matter and duration

We process personal data on your behalf only to provide the Service, for as long as you have an active account, or as otherwise agreed in writing.

2. Nature and purpose of processing

We process personal data as necessary to host, store, and process the content you upload (briefs, brand assets, feedback) and to render the videos you direct — no other purpose.

3. Categories of data and data subjects

The personal data processed depends entirely on what you choose to upload or include in your projects — typically, this may include names, images, or likenesses appearing in logos, screenshots, or brand assets you provide. The data subjects are whoever appears in or is identified by that content, most commonly your own employees, customers, or business contacts.

4. Our obligations as processor

As processor, we:

  • Process personal data only on your documented instructions, including regarding international transfers, unless required to do otherwise by EU or Lithuanian law.
  • Ensure our personnel are bound by confidentiality obligations.
  • Implement appropriate technical and organizational security measures (see our Privacy Policy, Section 10).
  • Do not engage a sub-processor without prior general authorization, and remain liable for any sub-processor’s performance.
  • Assist you, insofar as reasonably possible, in responding to data subject requests and in meeting your own GDPR obligations (security, breach notification, impact assessments).
  • Notify you without undue delay after becoming aware of a personal data breach affecting your data.
  • At your choice, delete or return all personal data at the end of the relationship, and delete existing copies unless retention is required by law.
  • Make available to you the information reasonably necessary to demonstrate compliance with this DPA, and allow for audits, subject to reasonable notice and confidentiality.

5. Sub-processors

You authorize us to engage the following categories of sub-processors to provide the Service, each bound by data protection terms consistent with this DPA:

  • Cloud hosting and compute — [provider name], for running the Service’s application and rendering infrastructure.
  • Object storage — [provider name], for storing uploaded assets and rendered video output.
  • Database and authentication — [provider name], for account data and project records.
  • Payment processing — [provider name], for billing (transaction data only, not full card numbers).

We will give you reasonable notice before adding or replacing a sub-processor, so you can object on reasonable data-protection grounds.

6. International transfers

Where a sub-processor is located outside the European Economic Area, we ensure the transfer is protected by an adequate safeguard, such as the European Commission’s Standard Contractual Clauses.

7. Liability

Liability under this DPA is subject to the limitation of liability set out in our Terms of Service.

8. Term and termination

This DPA remains in effect for as long as we process personal data on your behalf under the Terms of Service, and terminates automatically when that processing ends.

9. Contact us

Questions about this DPA, or a request for a signed copy, can be sent to legal@vellym.com, or by post at [registered office address], Lithuania.