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Open chat [ E-mail ](mailto:hello@lensgo.app) One thing before we start Leave your email address so we can reply, also when you have closed this page by then. Your email address That does not look like a valid email address. Could you double-check it? Start chat We only use it to reply to this conversation. Data Processing Agreement ========================= **Last update: 22 September 2026** This Data Processing Agreement (DPA), including Annexes 1–3, forms part of the LensGo Terms of Service or other service agreement between the Customer and Acosh, trading as LensGo (Agreement). It applies when LensGo processes personal data on the Customer’s behalf and takes precedence over conflicting terms on that processing. It continues until that data has been returned or deleted. 1 — Parties, scope and definitions [\#](#definitions) ------------------------------------------------------- Customer means the person or organisation identified in the Agreement and account registration. LensGo means Acosh, Sweelinckplantsoen 40, 1323 MT Almere, the Netherlands. The Customer is the controller and LensGo the processor of Customer Personal Data. Where the Customer acts as a processor for another controller, it confirms its authority to appoint LensGo as a subprocessor and to communicate that controller’s instructions. Services means the LensGo event photo and video sharing service, including collection, storage, organisation, moderation, display and downloading of event content. Customer Personal Data means personal data processed by LensGo on the Customer’s behalf to provide those Services. A Subprocessor is a provider engaged by LensGo to process that data on the Customer’s behalf. GDPR means Regulation (EU) 2016/679. Applicable Data Protection Law means the GDPR and applicable laws supplementing it. EEA means the European Economic Area. Controller, processor, personal data, processing, data subject, personal data breach and supervisory authority have their GDPR meanings. This DPA does not govern processing for which LensGo determines its own purposes, such as its account administration, billing, legal obligations and marketing. That processing is described in the Privacy Policy. A provider’s role depends on the particular processing; Annex 3 distinguishes these activities. 2 — Instructions and Customer responsibilities [\#](#processing) ------------------------------------------------------------------ LensGo shall process Customer Personal Data only on documented instructions from the Customer, including for international transfers, unless Union or Member State law requires otherwise. In that case LensGo shall inform the Customer of the legal requirement before processing, unless that law prohibits notice on important grounds of public interest. The Agreement, this DPA, the Customer’s service settings and written requests document the instructions. Annex 1 sets out their subject matter, duration, nature and purpose. The Customer determines the lawful basis, provides required notices, obtains any required consents and controls who may upload, view and download event content. The Customer may issue further lawful instructions through the contact in section 11. LensGo shall immediately inform the Customer if, in its opinion, an instruction infringes the GDPR or other Union or Member State data protection provisions. LensGo shall suspend the affected instruction until the parties resolve the issue; it shall not substitute its own purposes for the Customer’s instructions. 3 — Confidentiality and personnel [\#](#personnel) ---------------------------------------------------- LensGo shall restrict access to Customer Personal Data to authorised persons who need it to provide the Services. Those persons shall be bound by confidentiality commitments or an appropriate statutory duty of confidentiality and receive instructions appropriate to their responsibilities. These duties continue after their access ends. 4 — Security and assistance [\#](#security) --------------------------------------------- LensGo shall implement and maintain technical and organisational measures appropriate to the risk under Article 32 GDPR, taking account of the state of the art, implementation costs and the nature, scope, context and purposes of processing. Annex 2 specifies application controls and the operational obligations supporting them. Taking account of the nature of processing and information available to it, LensGo shall assist the Customer with compliance with Articles 32–36 GDPR, including security, breach assessment and notifications, data protection impact assessments and prior consultation with supervisory authorities. LensGo shall provide relevant information and cooperate with the competent supervisory authority. 5 — Subprocessors [\#](#subprocessing) ---------------------------------------- The Customer grants general written authorisation to use the Subprocessors listed in Annex 3 for the specified processing. LensGo shall notify the Customer by email at least 30 calendar days before adding or replacing a Subprocessor, identifying its function, processing locations and any international-transfer safeguards. Updating this webpage alone is not notice. The Customer may object on reasonable data protection grounds by contacting LensGo within that notice period. The parties shall work to resolve the objection, including by using an alternative or avoiding the affected processing. LensGo shall not give the proposed provider access to the objecting Customer’s data while the objection is unresolved. If no solution is available, the Customer may terminate the affected Services before the change takes effect and request return or deletion under section 9. Before giving access, LensGo shall enter into a written contract imposing the same data protection obligations as this DPA, including sufficient guarantees for appropriate technical and organisational measures. LensGo remains fully liable to the Customer for each Subprocessor’s performance of those obligations. On request, LensGo shall provide relevant compliance information and contractual safeguards, subject to necessary protection of confidential information. 6 — Responsibility [\#](#liability) ------------------------------------- Each party to this DPA commits to indemnify the other party for damages or expenses resulting from its own culpable infringement of this DPA, including any culpable infringement committed by its legal representative, subcontractors, employees or any other agents. Furthermore, each party commits to indemnify the other party against any claim exerted by third parties due to, or in connection with, any culpable infringement by the respectively other party. Each party is responsible for complying with its obligations under this DPA and Applicable Data Protection Law. Nothing in the Agreement or this DPA limits data subjects’ rights, either party’s liability under Article 82 GDPR, supervisory authorities’ powers or LensGo’s responsibility under section 5. 7 — Data subject rights [\#](#data-subject-rights) ---------------------------------------------------- Taking account of the nature of processing, LensGo shall assist the Customer through appropriate technical and organisational measures, insofar as possible, to respond to requests under Chapter III GDPR. This includes helping locate, export, rectify, restrict or erase relevant Customer Personal Data. LensGo shall promptly forward requests concerning Customer Personal Data to the Customer and shall not respond independently except on documented instructions or where law requires it. Where legally permitted, LensGo shall inform the Customer before responding under a legal requirement. 8 — Personal data breaches [\#](#data-breach) ----------------------------------------------- LensGo shall notify the Customer without undue delay after becoming aware of a personal data breach affecting Customer Personal Data. Notice shall describe the breach, categories and approximate numbers of affected people and records where known, likely consequences, measures taken or proposed and a contact for further information. Incomplete information shall be supplied in stages without undue further delay. LensGo shall investigate, contain and remedy the breach, preserve relevant evidence and cooperate with the Customer’s assessment, reporting and communications. The Customer decides on notifications to supervisory authorities and data subjects, without prejudice to LensGo’s own legal obligations. 9 — Return or deletion [\#](#deletion) ---------------------------------------- At the end of the Services involving processing, LensGo shall, at the Customer’s choice, return all Customer Personal Data in a commonly used electronic format and delete existing copies, or delete all Customer Personal Data and copies. The Customer may communicate its choice through section 11, including before termination. LensGo shall seek instructions if no choice has been communicated and shall not treat silence as a waiver of the right to return. LensGo shall complete the instructed return or deletion within 30 business days after the Services end or, if later, receipt of the Customer’s choice. Until completion, it shall protect the data under this DPA and process it only as needed for return, deletion or legally required retention. It shall procure the same action by Subprocessors and confirm completion in writing on request. These duties cover originals, derivatives, exports and backup copies. Union or Member State law requiring retention is the only exception: LensGo shall identify the legal requirement and retention period to the Customer unless prohibited, isolate the retained data, restrict processing to that requirement and delete it when the requirement ends. Backup copies must not be used for other purposes; any restoration must reapply deletion instructions. 10 — International transfers [\#](#data-transfer) --------------------------------------------------- EEA storage does not by itself exclude international transfers through support access, diagnostics or content delivery. LensGo shall transfer Customer Personal Data outside the EEA only on documented instructions and in compliance with Chapter V GDPR, including any onward transfers. Before a transfer, LensGo shall ensure that it is covered by an applicable adequacy decision or appropriate safeguards under Article 46 GDPR. Where relying on Commission Decision (EU) 2021/914 standard contractual clauses, LensGo shall execute the applicable module with the actual recipient, complete its annexes, assess the destination’s laws and practices and implement necessary supplementary measures. For a processor-to-subprocessor transfer this will ordinarily be Module Three. LensGo shall provide information about the applicable mechanism and safeguards on request and suspend transfers if adequate protection cannot be ensured. This DPA is an Article 28 processing agreement. It does not incorporate a set of international-transfer SCCs between the Customer and LensGo merely because LensGo receives data in the Netherlands. Any required SCCs apply to the actual transfer relationship; Annex 3 does not by itself constitute a transfer mechanism. 11 — Notices and contact [\#](#general-terms) ----------------------------------------------- Send instructions, objections, rights requests and compliance enquiries to hello@lensgo.app, addressed to Daan de Vos, Acosh / LensGo. LensGo shall send contractual notices and breach notifications to the Customer’s registered account email or a designated privacy contact. The Customer shall keep those details current. The parties shall protect confidential information obtained through this DPA. This does not prevent sharing this agreement or necessary compliance information with professional advisers, auditors, supervisory authorities or as required by law. 12 — Governing law and jurisdiction [\#](#governing-law) ---------------------------------------------------------- This DPA is governed by the law of the Netherlands. Disputes between the parties shall be submitted to the competent courts of the Netherlands, without prejudice to mandatory law, data subjects’ rights to bring proceedings or the powers of competent supervisory authorities. 13 — Compliance information and audits [\#](#audits) ------------------------------------------------------ LensGo shall make available all information necessary to demonstrate compliance with Article 28 GDPR and this DPA, and allow for and contribute to audits, including inspections, conducted by the Customer or an auditor mandated by it. The parties shall coordinate reasonable notice, confidentiality and measures to protect other customers’ data. Documents or independent reports may help satisfy an enquiry but shall not replace the right to an audit where further verification is needed. These arrangements shall not prevent or unreasonably delay an audit, especially following an incident or at a supervisory authority’s request. LensGo shall address identified deficiencies without undue delay. Annex 1 — Details of processing [\#](#annex-1) ------------------------------------------------ Parties and contacts: the Customer identified in the Agreement and its registered or designated contact; processor Acosh, trading as LensGo, Sweelinckplantsoen 40, 1323 MT Almere, the Netherlands, contact Daan de Vos at hello@lensgo.app. Their roles and responsibilities are described in sections 1 and 2. Subject matter and purpose: operating event albums and collecting, organising, sharing, displaying and exporting event photos, videos and related submissions at the Customer’s direction. Nature and frequency: ongoing collection and receipt of uploads and submissions, storage, retrieval, format conversion and thumbnail generation, organisation, moderation, display, transmission, downloading, access management and deletion while the Services are used. Data subjects: organisers and account holders, their staff and collaborators, guests and uploaders, people visible or audible in media, and other attendees or people identified in submissions. Personal data: names and email addresses where supplied; photos, faces, video and voices; captions, comments and form responses; filenames and file metadata (including capture time and location if present); event and uploader identifiers; IP addresses, browser/device information, timestamps and service access or activity records where collected in providing the Services. Sensitive data: media and free-text submissions may incidentally reveal health, religion, political opinions, sexual orientation or other special-category data, and may include children. The Customer determines any applicable Article 9 condition and additional safeguards, limits collection and access, and issues deletion instructions as needed. LensGo does not use event media for biometric identification. Duration: for the Services and the retention period under the Agreement, selected plan and documented Customer instructions, followed by return or deletion under section 9. Ending an event or payment period is not itself a statement that all media has already been erased. Annex 2 — Technical and organisational measures [\#](#annex-2) ---------------------------------------------------------------- Access controls: authenticated organiser accounts, hashed passwords, optional two-factor authentication, and authorisation checks for event management. Event settings support album passwords and moderation. Customers control sharing links and permissions; recipients can retain downloaded copies. Application safeguards: input validation, request throttling on protected endpoints, CSRF protection for browser state changes and restricted access to unpublished media. Application changes are subject to automated testing of relevant authentication, permissions and media operations. Operational obligations: LensGo shall restrict staff and service credentials by need, maintain confidentiality commitments, review access and remove it when no longer required. It shall maintain secure transport, timely security maintenance and incident handling under sections 3, 4 and 8. Availability and recovery: LensGo shall maintain recovery arrangements appropriate to the Article 32 risk assessment, regularly assess and test security and restoration measures, and apply the retention and deletion instructions to recovery copies. Information about current backup scope, locations, retention and recovery arrangements shall be made available under section 13. Scope of assurances: EU media storage is distinct from delivery and other processing. This annex does not claim end-to-end encryption, universal encryption at rest, independent certification or a particular recovery time. LensGo shall supply current infrastructure and security evidence on request under section 13 and shall not materially reduce the protection required by this DPA. Annex 3 — Subprocessors and other providers [\#](#sub-processors) ------------------------------------------------------------------- The following providers process Customer Personal Data when providing the indicated part of the Services. Changes are subject to section 5 and transfers to section 10. A provider’s place of establishment is not a guarantee that all processing occurs there. Hetzner — application hosting and database infrastructure in Germany; event records, account identifiers and data processed by the application. Bunny.net (Bunny Edge Storage) — storage and delivery of uploaded photos, videos, derivatives and downloadable archives; associated filenames, metadata and delivery request data. Media storage is in the European Union; delivery and remote access are also subject to section 10. Scaleway Transactional Email — transactional delivery in France; recipient addresses and service or event notification content. Cloudflare — reverse proxy, content delivery and traffic protection; request IP addresses, headers and content passing through the service. US provider with a global network; international processing is subject to section 10. Bugsink – Used for error monitoring; error reports may contain technical data such as IP addresses, user identifiers and request details (EU - FI/DE). Crisp — support where the Customer supplies event or guest data for assistance; contact details, messages and supplied attachments. French provider. Its handling of LensGo’s own customer relationship information falls under the separate role below. ### Providers for LensGo’s own purposes These activities are outside the Customer’s processing instructions and are covered by the Privacy Policy and the providers’ applicable terms. They do not make every listed provider a Subprocessor under this DPA; providers may act for LensGo as controller or as independent controllers for particular activities. Mollie: payments, subscriptions and billing. Google Sign-In and Sign in with Apple: optional account authentication. Google Ads: LensGo’s own advertising and conversion measurement. Crisp: LensGo’s own sales and account support. If one of these providers is to process Customer Personal Data on the Customer’s behalf beyond the activities listed above, LensGo shall first comply with sections 5 and 10. Event media is not authorised for LensGo’s own advertising by this DPA. [Privacy policy](https://lensgo.app/privacy-policy)