Last updated: June 4, 2026
1. Introduction, purpose and definitions
2. Rights and obligations of the data controller
The Data Controller is responsible for ensuring that the processing of Personal Data is carried out in accordance with GDPR (cf. GDPR Article 24), including applicable national privacy legislation and this Data Processing Agreement.
The Data Controller has the right and duty to make decisions regarding the purpose and the means to be used when processing Personal Data.
The Data Controller shall be responsible for ensuring that the Data Processor has sufficient instructions and information at all times to fulfill its obligations under the Data Processing Agreement and privacy regulations.
The Data Controller shall inform the data subjects concerned about the processing activities that the Data Processor will perform on behalf of the Data Controller under this Data Processing Agreement.
The Data Controller shall implement adequate technical and organizational measures to ensure and demonstrate compliance with GDPR.
The Data Controller shall report any personal data breaches to the relevant authorities and, if necessary, to the data subjects without undue delay in accordance with applicable law.
3. Instructions from the data controller
The Data Processor shall only process Personal Data in accordance with documented instructions from the Data Controller, unless otherwise required by EU or national law to which the Data Processor is subject. The Agreement (cf. definition in Section 1 of the Provider's Terms of Use) constitutes the instructions on the date this Data Processing Agreement is entered into. Instructions may also be given after the conclusion of the Agreement and the Data Processing Agreement. The Data Processor shall at all times be able to document such instructions.
Unless otherwise specified in the Data Processing Agreement, the Data Processor may use all appropriate technical aids (including computer systems and software) to fulfill the obligations incumbent upon the Data Processor.
If the Data Processor is of the opinion that instructions from the Data Controller violate data protection legislation, the Data Processor shall immediately inform the Data Controller of that opinion.
4. Confidentiality
The Data Processor shall ensure that employees and others who have access to Personal Data are authorized to process such Personal Data on behalf of the Data Processor. If such authorization expires or is revoked, access to the Personal Data shall be terminated without undue delay.
The Data Processor shall ensure that individuals authorized to process the Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality. This provision shall also apply after the termination of the Data Processing Agreement. The Data Processor shall, at the request of the Data Controller, be able to document the same.
5. Security of Processing
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, the Controller and the Processor shall consider implementing one or more of the following technical and organisational measures:
the pseudonymisation and encryption of Personal Data;
the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident;
a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
Pursuant to GDPR Article 32, the Processor shall also – independently of the Controller – evaluate the risks to the rights and freedoms of natural persons inherent in the processing and implement measures to mitigate those risks. For this purpose, the Controller shall provide the Processor with all information necessary to identify and evaluate such risks.
Furthermore, the Processor shall assist the Controller in ensuring compliance with the Controller’s obligations pursuant to GDPR Article 32, among other things by providing the Controller with information concerning the technical and organisational measures implemented by the Processor pursuant to GDPR Article 32 alongside other information necessary for the Controller to access in order to comply with the Controller’s obligation under GDPR Article 32.
Additional security measures will be implemented by the Processor, in accordance with the Processor's security policies.
6. Use of subcontractors
The processor shall meet the requirements of GDPR Article 28 (2) and (4) to engage another processor (a Sub-processor).
At the time of entering into the Data Processing Agreement, the Processor has the Controller's general authorization to engage Sub-processors. The Processor shall inform the Controller in writing of any intended changes concerning the addition or replacement of Sub-processors at least fourteen (14) days in advance, thereby giving the Controller the opportunity to object to such changes before the relevant Sub-processor is engaged. Approved Sub-processors at the entry into force of the Data Processing Agreement are specified in Appendix B to the Data Processing Agreement.
Sub-processors shall be made aware of the Processor's obligations under this Data Processing Agreement and the regulations governing the processing of the Controller's Personal Data, and shall be bound by the same obligations with respect to the protection of Personal Data as set out in this Data Processing Agreement, where the Sub-processor shall provide sufficient guarantees that appropriate technical and organizational measures will be implemented to ensure that the processing meets statutory requirements. The Processor shall remain fully liable to the Controller for the performance of the Sub-processor's obligations under its contract with the Processor. The Processor shall notify the Controller of any failures in the Sub-processor's compliance with its contractual obligations.
The Controller also has the right, upon written request, to receive copies of the relevant terms of the Processor's agreement with Sub-processors who are to process personal data on behalf of the Controller, subject to any limitations that may apply under law or regulation. Purely commercial terms cannot in any event be requested for disclosure.
The Processor shall enter into a third-party beneficiary clause with the Sub-processor, so that – in the event that the Processor has factually disappeared, ceased to exist in law, or has become insolvent – the Controller shall have the right to terminate the contract with the Sub-processor and instruct the Sub-processor to delete or return the Personal Data.
7. Transfer of personal data to third countries or international organizations
Any transfer of Personal Data to Third Countries or International Organizations shall only take place on the basis of documented instructions from the Data Controller and shall always be carried out in accordance with GDPR Chapter V.
In cases where transfer to Third Countries or International Organizations, which the Data Processor has not been instructed to perform by the Data Controller, is required under EU or national law to which the Data Processor is subject, the Data Processor shall inform the Data Controller of that legal requirement before the transfer takes place, unless that law prohibits such information on important grounds of public interest.
The Data Controller's instructions regarding the transfer of Personal Data to a Third Country, including, where applicable, the transfer mechanism under GDPR Chapter V on which the transfer is based, shall be specified in Annex B.1.
This Data Processing Agreement should not be confused with standard data protection clauses pursuant to GDPR Article 46 (2) (c) and (d), and this Data Processing Agreement cannot be considered a transfer mechanism under GDPR Chapter V.
8. Assistance to the controller
Taking into account the nature of the processing, the Data Processor shall assist the Controller by appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights laid down in GDPR Chapter III.
This means that the Data Processor shall, insofar as this is possible, assist the Controller in fulfilling:
the right to be informed when Personal Data are collected from the data subject
the right to be informed where Personal Data have not been obtained from the data subject
the data subject's right of access
the right to rectification
the right to erasure (»the right to be forgotten«)
the right to restriction of processing
notification obligation regarding rectification or erasure of Personal Data or restriction of processing
the right to data portability
the right to object
the right not to be subject to a decision based solely on automated processing, including profiling
In addition to the Data Processor's obligation to assist the Controller pursuant to Clause 5, the Data Processor shall furthermore, taking into account the nature of processing and the information available to the Data Processor, assist the Controller in ensuring compliance with:
The Controller's obligation to notify the personal data breach to the competent supervisory authority without undue delay and, where feasible, not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons;
The Controller's obligation to communicate the personal data breach to the data subject without undue delay, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons;
The Controller's obligation to carry out a data protection impact assessment (Data Protection Impact Assessment);
The Controller's obligation to consult the competent supervisory authority prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the Controller to mitigate the risk.
The Controller's obligation to ensure that the Personal Data are accurate and up to date, by informing the Controller without undue delay if the Data Processor becomes aware that the Personal Data being processed are inaccurate or outdated.
9. Notification of a Personal Data Breach
In the event of a personal data breach, the Data Processor shall, without undue delay after becoming aware of it, notify the Data Controller of the personal data breach.
The Data Processor's notification to the Data Controller shall, if possible, take place no later than 48 hours after the Data Processor became aware of the personal data breach, to enable the Data Controller to fulfill its obligation to report the personal data breach to the competent supervisory authority, cf. GDPR Article 33.
In accordance with Section 8, the Data Processor shall assist the Data Controller in reporting a personal data breach to the competent supervisory authority, which entails that the Data Processor is obliged to assist in obtaining the information described below, pursuant to GDPR Article 33(3):
a description of the nature of the personal data breach including, where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
the name and contact details of the data protection officer or other contact point where more information can be obtained;
a description of the likely consequences of the personal data breach;
a description of the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.
If it is not possible to provide all information in the first notification, the information shall be provided in phases as soon as it becomes available, without undue delay.
10. Deletion and return of personal data
The parties agree that upon termination of the Agreement (cf. Section 3 of the Provider's terms of use), this Data Processing Agreement shall also be deemed terminated.
Upon termination of the Agreement, the Data Processor is obliged to return all Personal Data to the Controller and delete existing copies when the agreement with the Controller ends, unless the Parties agree otherwise, and unless EU or national law requires the storage of the Personal Data.
For the avoidance of doubt, nothing in this Data Processing Agreement shall oblige the Data Processor to delete copies of Personal Data that it holds on its own behalf as a Controller (if any). Furthermore, nothing in this Data Processing Agreement shall oblige the Data Processor to delete data that is not Personal Data (either directly or indirectly) such as, but not limited to, sufficiently aggregated and/or sufficiently anonymized statistical data regarding the Controller's use and the Controller's end-users' use of the cloud-based accounting system Catacloud offered under the Agreement.
11. Audit and control
The Data Processor shall make available to the Data Controller all information necessary to demonstrate compliance with the obligations laid down in GDPR Article 28 and this Data Processing Agreement, and contribute to audits, including inspections, conducted by the Data Controller itself or by an auditor mandated by the Data Controller at reasonable intervals or if there are indications of non-compliance.
The Data Processor shall provide supervisory authorities, which under applicable law have access to the facilities of the Data Controller and the Data Processor, or representatives acting on behalf of such supervisory authorities, with access to the physical facilities of the Data Processor upon presentation of appropriate identification.
12. Other duties and rights
Other obligations and rights between the Parties are determined in the Agreement (cf. definition in section 1 of the Provider's terms of use).
The same contact persons under the Agreement will be the contact persons under this Data Processing Agreement.
Both Parties acknowledge that this Data Processing Agreement shall not expand the Controller's remedies for sanctions, including the Processor's liability for damages, beyond what follows from the Agreement (cf. section 13.3 of the Provider's terms of use), or GDPR. The Parties acknowledge that some of the obligations and areas of responsibility under GDPR differ from the remedies for sanctions in the Provider's terms of use.
Upon transfer of the Agreement to other parties (cf. section 5 of the Provider's terms of use), the Data Processing Agreement is considered transferred at the same time.
13. Disputes and Jurisdiction
This Data Processing Agreement shall be interpreted in its entirety in accordance with Norwegian law, with the exception of mandatory provisions of applicable data protection legislation.
Any dispute regarding the Data Processing Agreement, or dispute arising from this Data Processing Agreement, shall initially be resolved by the Parties through negotiation.
If a dispute is not resolved through negotiation, the dispute shall be submitted to the Oslo District Court (Oslo Tingrett), unless another mandatory jurisdiction applies according to applicable data protection legislation.
Appendix A. Information about the processing
A.2. The Data Processor's processing of Personal Data on behalf of the Data Controller shall essentially concern (the nature of the processing):
The nature of the processing may vary. The nature of the processing will include, but is not limited to, the collection of Personal Data, organization of Personal Data, storage of Personal Data, adaptation or alteration of Personal Data, transfer of Personal Data, analysis of Personal Data, or combinations of these.
Other processing activities may be carried out by the Data Processor for the purpose of fulfilling the Data Processor's obligations under the Agreement (cf. the definition in Section 1 of the Provider's Terms of Use).
A.3. The processing covers the following categories of Personal Data about data subjects:
Contact information such as names, email addresses, phone numbers, and physical addresses.
End-user employment and hiring information (and related details) such as date of birth, social security number / national identification number, nationality, gender, job title, department, start date, bank account information for salary payments, base salary, overtime hours and rates, bonus or incentive information, deductions and contributions (taxes, insurance premiums, pension funds), leave applications and approvals, attendance records (working hours, absences, tardiness).
System and usage data such as IP address, device information, logs.
Document metadata such as document names, author information, date and time of document creation or modification, tags or codes associated with documents.
Financial information to the extent necessary to perform compliance processes such as account closures, tax reporting, and auditing.
If it proves necessary to process more Personal Data than those listed above, such processing will take place in accordance with the instructions of the Controller, and/or because such processing is necessary to fulfill the Processor's obligations under the Agreement (cf. definition in Section 1 of the Supplier's Terms of Use).
A.4. Processing covers the following categories of data subjects:
Employees of the Data Controller (the Customer)
End users of the Data Controller (the Customer)
All other individuals / parties / users who interact with the cloud-based accounting system Catacloud, according to the instructions and authorization of the Data Controller, to upload, access, and process documents and data. This includes, for example, but is not limited to, Resellers who sell access to the Catacloud system and solution for their own account and act as independent business operators towards both the Provider and the Reseller's end customers.
Should it become necessary to process Personal Data regarding more categories of data subjects than those listed above, such processing will take place in accordance with instructions from the Data Controller, and/or because such processing is necessary to fulfill the Data Processor's obligations under the Agreement (cf. definition in section 1 of the Provider's terms of use).
A.5. Processing of Personal Data by the Data Processor on behalf of the Data Controller commences when this agreement enters into force. The processing has the following duration:
Throughout the duration/period of the Agreement (cf. section 3 of the Provider's terms of use).
Appendix B. Authorized Subprocessors
Approved subprocessors
Upon entering into the Agreement (cf. the definition in section 1 of the Provider's terms of use) and this Data Processing Agreement, the Data Controller has approved the use of the following Subprocessors:
Catacloud
Rolfsbuktveien 2, 1364 Fornebu, Norway
All processing takes place within the EU/EEA
To the solution/accounting system accessible at app.catacloud.com and used by the customer.
ZTL
Kristian IVs gate 15, 0164 Oslo, Norway
All processing takes place within the EU/EEA
Enables users to initiate secure and convenient payment transactions directly from their accounts.
Nets (Mastercard)
Nets Branch Norway, Haavard Martinsens vei 54, 0978 Oslo
All processing takes place within the EU/EEA
Facilitates secure and efficient payment transactions between merchants, cardholders, and issuing banks.
ECIT Digital
Stadionveien 4, 7898 Limingen, Norway
All processing takes place within the EU/EEA
Manage and organize documents in a digital format, making storage, retrieval, and tracking easy.
Intect
Hørkær 12A, 2730 Herlev, Denmark
All processing takes place within the EU/EEA
Administration of payroll and wage payment processes to employees.
Amazon Web Services
One Burlington Plaza, Burlington Road, Dublin 4, D04 RH96, Ireland
All processing takes place within the EU/EEA
Hosting and storage of personal data.
Intecom
55 2nd Street, 4th Floor, San Francisco, CA 94105, USA
Data is stored with AWS, Northern Virginia, USA.
A communication platform for customer support, user management, and communication between Catacloud and end-users.
Cradl.ai, Lucidtech AS
Kongens gate 12, 0153 Oslo, Norway
Data is stored with AWS, Northern Virginia, USA.
Automated document interpretation and data extraction using AI, to organize and make accounting and supporting document data accessible.
JCloud AS
Inkognitogata 33A, 0256 Oslo, Norway
All processing takes place within the EU/EEA
Secure storage, backup, and management of data, including personal data, in cloud-based infrastructure.
The controller has, at the commencement of the Agreement and this Data Processing Agreement, approved the use of the aforementioned Subprocessors for the processing described for each respective party.
B.2. General authorization of the data controlle
Subject to the limitations explicitly mentioned in this Data Processing Agreement, and subject to applicable limitations under the GDPR, the Controller provides a general consent for the Processor to, during the term of the Agreement (cf. Section 3 of the Supplier's Terms of Use), use standard software from Amazon and the other Sub-processors listed under Appendix B, Section B.1, to fulfill the Processor's obligations under the Agreement (cf. definition in Section 1 of the Supplier's Terms of Use). Furthermore, the Controller agrees that such processing is supported by servers in Third Countries.
The agreed advance notice periods for authorization to add and/or change Sub-processors are at least fourteen (14) days. Controllers have the opportunity to object to such changes within the aforementioned deadline. If no objection from the Controller is received by the deadline mentioned above at the latest, the relevant Sub-processor shall be deemed accepted by the Controller.