IRONKEEP Data Processing Addendum

Effective Date: July 21, 2026 | Last Updated: July 23, 2026

This Data Processing Addendum, including its Annexes (the “DPA”), forms part of and is incorporated by reference into the IRONKEEP Terms of Service (the “Agreement”) between DatumWard Technologies, LLC (“IRONKEEP,” “we,” “us,” or “our”), operating the IRONKEEP platform, and the Customer (“Customer,” “you,” or “your”). This DPA applies to the extent IRONKEEP processes Personal Data contained within Customer Data on the Customer’s behalf in connection with the Services.

Capitalized terms not defined in this DPA have the meanings given to them in the Agreement. In the event of any conflict between this DPA and the remainder of the Agreement with respect to the processing of Personal Data, this DPA prevails (see Section 3).

1. Parties and Roles

1.1 Subject of this DPA. IRONKEEP provides the IRONKEEP platform and its products: IRONKEEP MAIL (email, calendar, and contacts), IRONKEEP DRIVE (file storage and document editing), IRONKEEP CHAT (team chat), and IRONKEEP MEETINGS (audio, video, and screen-share meetings), together with shared identity, data-protection, retention, audit, and access controls (collectively, the “Services”). In delivering the Services, IRONKEEP may process Personal Data that the Customer or its Authorized Users submit to or generate through the Services.

1.2 Roles of the parties. For the purposes of applicable Data Protection Law:

The Customer is the controller (or, where the Customer processes Personal Data on behalf of one or more third parties, a processor) of the Personal Data within Customer Data.
IRONKEEP is the processor (or, where the Customer acts as a processor, a sub-processor) of that Personal Data, and processes it only on the Customer’s behalf and in accordance with this DPA.

1.3 Free-tier individuals. Where an individual self-registers under the shared, platform-operated free-tier Organization, that individual is the Customer for purposes of the Agreement and this DPA, binds themselves to its terms, and is the controller of the Personal Data they submit. The free tier is provided on an “as-is” basis and may be changed or discontinued, as described in the Agreement.

1.4 Account Data. IRONKEEP processes Account Data (registration, administrative-contact, and billing information) as a controller for its own legitimate business purposes, including establishing, managing, securing, and billing the Customer’s account. IRONKEEP’s processing of Account Data as a controller is governed by the IRONKEEP Privacy Policy, not by this DPA.

2. Definitions

2.1 The following terms have the meanings set out below. Terms such as “controller,” “processor,” “data subject,” “personal data,” “processing,” “personal data breach,” and “supervisory authority” have the meanings given under the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and, where applicable, the UK GDPR and the Swiss Federal Act on Data Protection. Terms such as “business,” “service provider,” “consumer,” “sell,” “share,” and “personal information” have the meanings given under the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, “CCPA/CPRA”).

“Data Protection Law” means all data protection and privacy laws applicable to the processing of Personal Data under the Agreement, including the GDPR, the UK GDPR, the Swiss FADP, and the CCPA/CPRA, in each case as amended or superseded from time to time.
“Customer Data” means data submitted to or processed through the Services by or on behalf of the Customer or its Authorized Users, including emails, files, documents, chat messages, calendar events, contacts, and meeting metadata.
“Account Data” means the registration, administrative-contact, and billing information IRONKEEP collects to establish, manage, and bill the Customer’s account.
“Personal Data” or “Personal Information” has the meaning given to that term in the Agreement (information relating to an identified or identifiable natural person, as defined under applicable Data Protection Law). For purposes of this DPA only, references to Personal Data are scoped to such information within Customer Data that IRONKEEP processes on the Customer’s behalf; this scoping does not alter the meaning of the defined term in the Agreement.
“Authorized User” means an individual the Customer provisions and permits to use the Services under the Customer’s account.
“Organization” means the Customer’s account and workspace on the Services.
“Subprocessor” means a third party engaged by IRONKEEP to process Customer Data on its behalf.
“Standard Contractual Clauses” or “SCCs” means the standard contractual clauses for the transfer of personal data to third countries adopted by the European Commission in Implementing Decision (EU) 2021/914, as amended or replaced.
“Data Subject Request” means a request from a data subject to exercise rights under Data Protection Law (such as access, rectification, erasure, restriction, portability, or objection, or the equivalent consumer rights under the CCPA/CPRA).

2.2 Defined terms used and not otherwise defined in this DPA — including “Services,” “Customer Data,” “Account Data,” “Organization,” “Authorized User,” “AUP,” and “DPA” — have the meanings given in the Agreement.

3. Scope, Roles, and Order of Precedence

3.1 Scope. This DPA applies only to IRONKEEP’s processing of Personal Data within Customer Data on the Customer’s behalf in the course of providing the Services. It does not apply to Personal Data that IRONKEEP processes as a controller (including Account Data), which is governed by the IRONKEEP Privacy Policy.

3.2 Duration. This DPA takes effect on the Effective Date of the Agreement (or, if later, the date the Customer accepts this DPA) and remains in force for as long as IRONKEEP processes Personal Data on the Customer’s behalf, including through the return-and-deletion obligations in Section 14.

3.3 Order of precedence. In the event of any conflict or inconsistency among the documents that make up the Agreement with respect to the processing of Personal Data, the following order of precedence applies: (a) the applicable Standard Contractual Clauses or other transfer mechanism (where incorporated under Section 13); (b) this DPA; and (c) the remainder of the Agreement. In all other respects, the Agreement remains in full force and effect.

4. Processing Instructions

4.1 Documented instructions. IRONKEEP will process Personal Data only on the Customer’s documented instructions, including with regard to international transfers, unless required to do otherwise by applicable law to which IRONKEEP is subject. The Customer’s documented instructions comprise: (a) the Agreement, including this DPA; (b) the configuration choices and settings the Customer and its Authorized Users select within the Services, including identity, sharing, retention, legal-hold, data-protection, and access settings; and (c) the Customer’s lawful use of the Services in accordance with their documented functionality.

4.2 Additional instructions. Any additional or alternative instructions must be agreed in writing by the parties. IRONKEEP may, but is not obligated to, comply with instructions that fall outside the scope of the Services as documented, and may condition compliance on agreement of additional fees or terms.

4.3 Notice of unlawful instructions. IRONKEEP will inform the Customer if, in IRONKEEP’s reasonable opinion, an instruction infringes Data Protection Law, unless prohibited from doing so by law. IRONKEEP is not obligated to perform a legal review of the Customer’s instructions and gives no assurance that any instruction complies with applicable law.

4.4 Required-by-law processing. Where applicable law requires IRONKEEP to process Personal Data other than on the Customer’s instructions, IRONKEEP will inform the Customer of that legal requirement before processing, unless the law prohibits such notice on important grounds of public interest.

5. Customer Obligations

5.1 Lawful basis and notices. The Customer is responsible for ensuring that it has a valid legal basis for the processing of Personal Data through the Services and for providing all notices to, and obtaining all consents and authorizations from, data subjects required under Data Protection Law for IRONKEEP to process Personal Data as contemplated by the Agreement and this DPA.

5.2 Lawfulness of instructions and data. The Customer represents and warrants that its instructions, and the Customer Data it submits, comply with Data Protection Law, and that the Customer has the right to transfer, or provide access to, the Personal Data to IRONKEEP and its Subprocessors for processing in accordance with the Agreement.

5.3 Accuracy and configuration. The Customer is responsible for the accuracy of the Personal Data it submits and for configuring the Services, including identity, sharing, retention, legal-hold, data-protection, role, and access controls, appropriately for its compliance needs. The Customer is responsible for the acts and omissions of its Authorized Users.

5.4 Special categories. The Customer is solely responsible for determining whether to submit Personal Data revealing special categories of data (as described in Annex I) through the Services and for ensuring it does so lawfully. The Services are general-purpose productivity tools and are not designed or marketed for the processing of special-category data.

6. IRONKEEP (Processor) Obligations

6.1 IRONKEEP will:

(a) process Personal Data only on the Customer’s documented instructions, as set out in Section 4;
(b) ensure that personnel authorized to process Personal Data are bound by appropriate obligations of confidentiality (Section 7);
(c) implement and maintain the technical and organizational security measures described in Section 8 and Annex II;
(d) engage Subprocessors only in accordance with Section 9;
(e) taking into account the nature of the processing, assist the Customer by appropriate technical and organizational measures, insofar as possible, in responding to Data Subject Requests (Section 10);
(f) assist the Customer in ensuring compliance with its obligations relating to security of processing, personal-data-breach notification, data protection impact assessments, and prior consultation (Sections 11 and 12), taking into account the nature of processing and the information available to IRONKEEP;
(g) make available to the Customer information reasonably necessary to demonstrate compliance with this DPA and allow for and contribute to audits, as described in Section 15; and
(h) at the Customer’s choice, return or delete Personal Data at the end of the provision of the Services, as described in Section 14.

6.2 The Customer acknowledges that IRONKEEP may be entitled to recover the reasonable costs of providing assistance under Sections 6.1(e), (f), 11, 12, and 15 to the extent permitted by Data Protection Law and where such assistance exceeds the functionality made available within the Services.

7. Confidentiality

7.1 IRONKEEP will treat Personal Data as confidential and will ensure that any person it authorizes to process Personal Data is subject to a duty of confidentiality (whether contractual or statutory) and processes Personal Data only as necessary to perform the Services and on IRONKEEP’s instructions consistent with this DPA.

7.2 IRONKEEP limits access to Personal Data to those personnel who require access to perform the Agreement, and applies role-based access controls and least-privilege principles to that access, as further described in Annex II.

8. Security Measures

8.1 Technical and organizational measures. IRONKEEP implements and maintains appropriate technical and organizational measures designed to protect Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, damage, alteration, or disclosure, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing. These measures are described in Annex II and include, among others:

encryption at rest and in transit;
logical isolation of Customer Data;
restricted administrative access to Customer content;
multi-factor authentication, role-based access controls, and least-privilege access;
security monitoring, logging, and threat detection;
customer-configurable data-protection controls; and
rate limiting and controlled software-development and deployment practices.

8.2 Updates to measures. IRONKEEP may update or modify the security measures from time to time, provided that such updates do not materially reduce the overall level of protection of Personal Data during the term of the Agreement.

8.3 Customer responsibilities. The Customer is responsible for its own use of the Services, including securing its account credentials, configuring available identity, access, data-protection, and retention controls, and managing the access rights of its Authorized Users.

9. Subprocessors

9.1 General authorization. The Customer provides a general authorization for IRONKEEP to engage Subprocessors to process Customer Data, subject to this Section 9. The Subprocessors engaged as of the Effective Date are listed in Annex III, which references the IRONKEEP Subprocessors list.

9.2 Flow-down obligations. IRONKEEP will impose on each Subprocessor, by written contract, data protection obligations that are substantially the same as and no less protective than those set out in this DPA, to the extent applicable to the nature of the services provided by the Subprocessor.

9.3 Liability. IRONKEEP remains fully liable to the Customer for the performance of each Subprocessor’s data protection obligations to the same extent IRONKEEP would be liable if performing the services of the Subprocessor directly under this DPA.

9.4 Notice of changes and right to object. IRONKEEP will give the Customer prior notice of the addition or replacement of any Subprocessor (for example, by updating the IRONKEEP Subprocessors list and/or providing a notification mechanism to which the Customer may subscribe), thereby giving the Customer the opportunity to object on reasonable data-protection grounds before the new Subprocessor begins processing Customer Data. If the Customer reasonably objects and the parties cannot resolve the objection, the Customer may, as its sole and exclusive remedy, terminate the affected portion of the Services in accordance with the Agreement.

9.5 Primary infrastructure provider. The Customer acknowledges that the Services are hosted by the infrastructure provider identified in Annex III and the IRONKEEP Subprocessors list, in United States environments, including specialized government environments where supported.

9.6 Customer-configured third parties. Identity, authentication, and user-provisioning services configured and controlled by the Customer are not Subprocessors of IRONKEEP. The Customer is responsible for its relationships with, and the configuration of, those third parties.

10. Data Subject Requests

10.1 Routing of end-user requests. Because IRONKEEP processes Personal Data on the Customer’s behalf, IRONKEEP will, to the extent legally permitted, promptly notify the Customer if IRONKEEP receives a Data Subject Request relating to the Customer’s Personal Data, and will not respond to such a request directly except on the Customer’s documented instructions or as required by applicable law. IRONKEEP will direct the data subject to the Customer.

10.2 Assistance. Taking into account the nature of the processing, IRONKEEP will provide reasonable assistance, including through the self-service functionality of the Services (such as administrative consoles, search, export, deletion, and legal-hold controls), to enable the Customer to respond to Data Subject Requests as required under Data Protection Law.

11. Personal Data Breach Notification

11.1 Notification. IRONKEEP will notify the Customer without undue delay after becoming aware of a personal data breach affecting the Customer’s Personal Data processed by IRONKEEP.

11.2 Information provided. The notification will, to the extent then known to IRONKEEP, describe the nature of the personal data breach, the categories and approximate number of data subjects and records concerned, the likely consequences, and the measures taken or proposed to address the breach and mitigate its effects. Where it is not possible to provide all such information at once, IRONKEEP may provide it in phases without undue further delay.

11.3 Cooperation. IRONKEEP will reasonably cooperate with the Customer and take such reasonable steps as the Customer directs to assist in the investigation, mitigation, and remediation of the personal data breach.

11.4 No admission. IRONKEEP’s notification of, or response to, a personal data breach under this Section is not an acknowledgment by IRONKEEP of any fault or liability with respect to the breach.

12. Data Protection Impact Assessments and Prior Consultation

12.1 Taking into account the nature of the processing and the information available to IRONKEEP, IRONKEEP will provide the Customer with reasonable assistance with data protection impact assessments and prior consultations with supervisory authorities that the Customer reasonably considers to be required under Articles 35 and 36 of the GDPR (or equivalent provisions of other Data Protection Law), in each case solely in relation to the processing of Personal Data by IRONKEEP under this DPA. Such assistance may be provided through documentation about the Services and the security measures described in Annex II.

13. International Transfers

13.1 Hosting locations. The Services are hosted in the United States. The Customer acknowledges that Personal Data may be processed in the United States and by the Subprocessors listed in Annex III.

13.2 Transfer mechanism. To the extent the Customer’s transfer of Personal Data to IRONKEEP, or IRONKEEP’s processing of that Personal Data, constitutes a restricted transfer under the GDPR, UK GDPR, or Swiss FADP for which an appropriate safeguard is required, the parties agree that the Standard Contractual Clauses are incorporated into and form part of this DPA by reference and apply to such transfer, completed as follows:

(a) Module Two (controller-to-processor) applies where the Customer is a controller; Module Three (processor-to-processor) applies where the Customer is a processor;
(b) in Clause 7, the optional docking clause applies;
(c) in Clause 9, Option 2 (general written authorization) applies, with the notice period set out in Section 9.4;
(d) in Clause 11, the optional independent dispute-resolution language does not apply;
(e) in Clause 17, the SCCs are governed by the law of an EU Member State that allows for third-party beneficiary rights; absent another agreed Member State, the governing law is the law of the EU Member State of the competent supervisory authority identified under Annex I, and where the parties have agreed a default it is the law of Ireland. The law of Delaware governs the remainder of the Agreement except to the extent the SCCs require otherwise;
(f) in Clause 18, disputes arising from the SCCs are resolved before the courts of the EU Member State whose law governs the SCCs under subsection (e); the courts of Delaware retain jurisdiction over the remainder of the Agreement except to the extent the SCCs require otherwise; and
(g) the information required to complete the Annexes to the SCCs is set out in Annexes I, II, and III of this DPA.

13.3 UK transfers. For transfers subject to the UK GDPR, the parties incorporate the UK International Data Transfer Addendum issued by the UK Information Commissioner (“UK Addendum”). The UK Addendum amends the SCCs as set out therein and is completed as follows: (a) Table 1 (parties) is completed using the party details in Annex I and the Contact section of this DPA; (b) Table 2 selects the SCC Module and options identified in Section 13.2; (c) Table 3 (appendix information) is completed using Annexes I, II, and III of this DPA; and (d) in Table 4, neither party may end the UK Addendum when the Approved Addendum changes, except as permitted by the UK Addendum. The competent supervisory authority for UK transfers is the UK Information Commissioner’s Office (ICO).

13.4 Swiss transfers. For transfers subject to the Swiss FADP, the SCCs apply with the following modifications: (a) references to the GDPR are read as references to the Swiss FADP to the extent the transfer is governed by it; (b) the competent supervisory authority is the Swiss Federal Data Protection and Information Commissioner (FDPIC); (c) references to EU Member States are read so as not to deprive data subjects in Switzerland of the right to bring proceedings in their place of habitual residence; and (d) the protections extend to data of legal entities until the entry into force of revised FADP provisions that no longer require them. In all other respects the SCC selections in Section 13.2 apply.

13.5 Alternative mechanisms. If the SCCs or any other transfer mechanism incorporated under this Section is invalidated, superseded, or replaced, the parties will work in good faith to implement an alternative lawful transfer mechanism.

13.6 Government deployments. Where the Customer requires a specialized government cloud environment or other specific data-residency or compliance arrangements, those arrangements are addressed under a separate written agreement (for example, an ENTERPRISE order).

14. Return and Deletion of Personal Data

14.1 Export window on termination. Following expiration or termination of the Agreement, the Customer has 30 days to export its Customer Data using the export functionality made available through the Services.

14.2 Deletion. At the Customer’s choice, IRONKEEP will delete or return the Personal Data after the end of the provision of the Services and delete existing copies, except to the extent applicable law requires storage of the Personal Data. Temporary email-processing copies expire after approximately 7 days. Files placed in trash are purged after 30 days unless subject to a legal hold. Following organization offboarding or deletion, IRONKEEP’s secure deletion process generally makes Customer Data unrecoverable within approximately 30 days and may include cryptographic erasure.

14.3 Legal holds. Personal Data subject to a legal hold is preserved until the hold is released by the Customer, notwithstanding the deletion timelines above. The Customer is responsible for managing and releasing its own legal holds.

14.4 Legal retention exceptions. IRONKEEP may retain Personal Data to the extent, and for so long as, required by applicable law, and in such case will continue to protect it in accordance with this DPA and limit its processing to the purposes that prevent deletion.

14.5 Certification. Upon the Customer’s written request, IRONKEEP will confirm in writing that it has complied with its deletion obligations under this Section, subject to the exceptions described above.

15. Audit Rights

15.1 Information and reports. IRONKEEP will make available to the Customer information reasonably necessary to demonstrate compliance with this DPA, including, where available, relevant third-party attestations and certifications covering the underlying infrastructure, together with IRONKEEP’s own documentation describing the technical and organizational security measures set out in Annex II.

15.2 Reliance on infrastructure-provider attestations. The Customer acknowledges that the underlying cloud infrastructure is operated by a third-party provider and that the Customer’s audit rights with respect to that infrastructure are satisfied by the provider’s independent third-party attestations and certifications, which IRONKEEP will make available or identify upon reasonable request to the extent IRONKEEP is permitted to do so.

15.3 On-site audits. Where the information made available under Sections 15.1 and 15.2 is insufficient to demonstrate compliance, IRONKEEP will allow for and contribute to audits, including inspections, conducted by the Customer or an independent auditor mandated by the Customer (and reasonably acceptable to IRONKEEP), subject to the following: such audits occur no more than once per twelve (12) months (except where required by a supervisory authority or following a personal data breach), on at least thirty (30) days’ prior written notice, during normal business hours, in a manner that minimizes disruption, subject to confidentiality obligations, and excluding access to other customers’ data, IRONKEEP’s proprietary or commercially sensitive information, or anything that would compromise IRONKEEP’s security or legal obligations. The Customer bears its own and IRONKEEP’s reasonable costs of any on-site audit.

16. CCPA/CPRA

16.1 Service provider status. To the extent IRONKEEP processes Personal Information subject to the CCPA/CPRA on the Customer’s behalf, IRONKEEP acts as a “service provider” and the Customer acts as a “business” (or, where the Customer is itself a service provider, as a service provider).

16.2 Restrictions on use. IRONKEEP will not:

(a) sell or share the Personal Information (as those terms are defined under the CCPA/CPRA);
(b) retain, use, or disclose the Personal Information for any purpose other than for the specific purpose of performing the Services specified in the Agreement, or as otherwise permitted by the CCPA/CPRA;
(c) retain, use, or disclose the Personal Information outside the direct business relationship between IRONKEEP and the Customer; or
(d) combine the Personal Information with personal information received from, or on behalf of, another person, or collected from IRONKEEP’s own interactions with the consumer, except as permitted by the CCPA/CPRA.

16.3 Certification. IRONKEEP certifies that it understands the restrictions in this Section 16 and will comply with them.

16.4 Assistance and notice. IRONKEEP will provide reasonable assistance to the Customer in responding to verifiable consumer requests under the CCPA/CPRA, as described in Section 10. IRONKEEP will notify the Customer if it determines that it can no longer meet its obligations under the CCPA/CPRA, and the Customer may, upon notice, take reasonable and appropriate steps to stop and remediate unauthorized use of Personal Information.

17. Liability

17.1 Each party’s liability arising out of or related to this DPA, whether in contract, tort, or under any other theory of liability, is subject to the limitations and exclusions of liability set out in the Agreement, and any reference in the Agreement to a party’s liability means the aggregate liability of that party under the Agreement and this DPA together.

17.2 Nothing in this DPA limits or excludes any liability that cannot be limited or excluded under applicable law, and nothing in this Section 17 affects the rights of data subjects under the Standard Contractual Clauses or Data Protection Law.

18. Annexes

This DPA includes the following Annexes, which form an integral part of it.

Annex I — Details of Processing

A. Subject matter. IRONKEEP’s provision of the Services to the Customer under the Agreement, including IRONKEEP MAIL, IRONKEEP DRIVE, IRONKEEP CHAT, IRONKEEP MEETINGS, and the shared platform controls.

B. Duration of the processing. For the term of the Agreement and until the deletion of Personal Data in accordance with Section 14 of this DPA.

C. Nature and purpose of the processing. Hosting, storage, transmission, indexing, encryption, backup, and retrieval of Customer Data; providing email, calendar, contact, file, document, chat, and meeting functions; screening inbound-email links for safety; applying customer-configured data-protection, retention, legal-hold, audit, identity, and access controls; and billing for paid tiers — in each case to provide and support the Services as documented and on the Customer’s instructions.

D. Categories of data subjects. The Customer’s Authorized Users; the Customer’s contacts and address-book entries; email, calendar, and chat correspondents and meeting participants; and any other individuals whose Personal Data is included in Customer Data submitted to the Services.

E. Categories of Personal Data.

Identifiers and contact details (e.g., names, email addresses, usernames, user identifiers);
Communications content (e.g., email bodies and headers, chat messages, attachments);
Calendar and contact data (e.g., events, invitations, attendee lists, contact cards);
File and document content stored in or edited through IRONKEEP DRIVE;
Meeting metadata for IRONKEEP MEETINGS;
Authentication and access data (e.g., identity attributes and role assignments);
Usage, log, and network-location data generated through use of the Services, including for access controls, security monitoring, and audit logging.

F. Special categories of data. The Services are not designed for special-category data. Any special categories of Personal Data (as defined under Article 9 of the GDPR) are processed only if and to the extent the Customer or its Authorized Users choose to submit them within Customer Data, at the Customer’s sole discretion and responsibility (see Section 5.4). Where submitted, such data is subject to the same technical and organizational measures described in Annex II.

G. Frequency of processing. Continuous, for the duration of the Agreement.

H. Identity of controller and processor. The Customer is the controller (or processor); IRONKEEP (DatumWard Technologies, LLC) is the processor (or sub-processor).

I. Competent supervisory authority. Where the SCCs apply, the competent supervisory authority is determined in accordance with Clause 13 of the SCCs and the GDPR (or, for UK or Swiss transfers, the UK ICO or the Swiss FDPIC respectively).

Annex II — Technical and Organizational Security Measures

IRONKEEP implements and maintains at least the following measures, as further described in Section 8:

1. Encryption.

Encryption at rest and in transit.
Encryption keys and access controls are managed to isolate Customer Data and restrict administrative access to Customer content.

2. Access control and identity.

Multi-factor authentication and password-policy controls.
Role-based and least-privilege access.
Customer-controlled identity, authentication, and user-provisioning services.
Customer-configurable location-based access controls.

3. Separation of Customer Data.

Customer Data is logically isolated across application, storage, and encryption layers.
Cross-customer access is prohibited.

4. Logging, monitoring, and detection.

Centralized security logging, monitoring, and threat detection.
Audit logs available to the Customer.

5. Data loss prevention.

Customer-configurable data-protection controls for outbound communications and stored content.

6. Platform and application hardening.

Layered defenses, rate limiting, and protective response headers.
Controlled software releases and change-management practices.

7. Resilience and data lifecycle.

Documented retention and deletion schedules.
Temporary email-processing copies expire after approximately 7 days.
Items placed in trash are purged after 30 days unless subject to a legal hold.
Secure deletion generally makes Customer Data unrecoverable within approximately 30 days following organization offboarding or deletion.

8. Subprocessor management.

Engagement of Subprocessors under written contracts with data protection obligations no less protective than this DPA (Section 9).

9. Compliance posture (informational).

The Services are architected and designed to align with the FedRAMP Moderate baseline and NIST SP 800-53 controls and to support FedRAMP-oriented and government workloads. IRONKEEP is not currently FedRAMP authorized or certified, holds no Authorization to Operate, and is not on the FedRAMP Marketplace. Nothing in this DPA constitutes a representation of certification, authorization, or audited compliance. Specific certification requirements, if any, are addressed under a separate written agreement (for example, an ENTERPRISE order).

Annex III — List of Subprocessors

The IRONKEEP Subprocessors list is the controlling, authoritative record of IRONKEEP’s current Subprocessors. It is incorporated into this DPA by reference and is updated by IRONKEEP in accordance with Section 9. As of the Effective Date, IRONKEEP’s Subprocessors comprise:

Amazon Web Services, Inc. — cloud hosting and infrastructure used to provide the Services.
Stripe, Inc. — payment processing and subscription billing for paid plans.
Google LLC — link-reputation screening for inbound email.

Identity, authentication, and user-provisioning services configured and controlled by the Customer are not IRONKEEP Subprocessors.

Contact

Questions about this DPA, or requests to execute it (including the Standard Contractual Clauses), may be directed to:

Data protection / DPO: security@ironkeep.us
Privacy inquiries: security@ironkeep.us
Legal notices: legal@ironkeep.us
Security: security@ironkeep.us
Mailing address: 2221 Yellowstone Ranch Court, Waxahachie, TX 75165, United States
Phone: +1 703-338-6561
Website: https://www.ironkeep.us/

DatumWard Technologies, LLC, a limited liability company organized in Delaware, operates the IRONKEEP platform.

This DPA is governed by the law of Delaware, and the parties submit to the courts located in Delaware, except as otherwise required by the Standard Contractual Clauses or applicable Data Protection Law.