Data Processing Agreement

For repair shops using Aurora Automotive · Effective 19 October 2026

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1. 1. Parties and when this applies
2. 2. Words used here
3. 3. What we process, and why
4. 4. The shop’s part
5. 5. Instructions
6. 6. Confidentiality
7. 7. Security
8. 8. Sub-processors
9. 9. Transfers outside Moldova
10. 10. Help with people’s requests
11. 11. Personal data breaches
12. 12. Return and deletion
13. 13. Information and audits
14. 14. Liability, term and law
15. Annex A. Security measures
16. Annex B. Sub-processors

1. Parties and when this applies

This agreement is between the business that keeps its records in Aurora Automotive (the “shop”, the controller) and Roman Zubenco, a private individual resident in the Republic of Moldova, who operates Aurora (“we”, the processor).

It forms part of the Terms of Use and applies, without a separate signature, from the moment a shop keeps records in Aurora Automotive. The person who connects the shop confirms that they may accept it for the shop. On personal data, where this agreement and the Terms of Use differ, this agreement prevails. Requirements of the EU General Data Protection Regulation (GDPR, Article 28) and of the data protection law of the Republic of Moldova that are not repeated here still apply where those laws do.

2. Words used here

“Personal data”, “processing”, “controller”, “processor”, “data subject” and “personal data breach” mean what the GDPR and the data protection law of the Republic of Moldova say they mean. “Records” means everything the shop and its people put into Aurora Automotive, or import into it.

3. What we process, and why

4. The shop’s part

The shop:

• has a lawful basis for every record it keeps, and gives its clients and people the information the law requires;
• keeps its records accurate, and does not record more than it needs;
• decides who may work in the shop in Aurora Automotive, and removes people who should no longer have access;
• gives only lawful instructions.

5. Instructions

We process the records only on the shop’s documented instructions. Those instructions are this agreement, the Terms of Use, and what the shop and its people do in Aurora Automotive: what they record, change, export, import or delete. We may also process them where a law requires it; we will tell the shop first, unless the law forbids that. If we believe an instruction breaks data protection law, we will say so and need not follow it.

6. Confidentiality

Only the operator has access to the records, and only as far as running, supporting and securing the service requires. Anyone else we ever allow to access them will be bound by confidentiality first. We do not look at a shop’s records except to fix a problem, answer the shop’s own request, or protect the service.

7. Security

We take the technical and organisational measures in Annex A, and keep them appropriate to the risk as the service and the threats change. We may improve them; we will not reduce the overall level of protection.

8. Sub-processors

The shop authorises the sub-processors listed in Annex B. We impose on each one data protection obligations that protect the records at least as well as this agreement, and we remain responsible to the shop for them.

Before we add or replace a sub-processor, we will tell the shop’s administrators by email at least 30 days in advance, and update Annex B. The shop may object on reasonable data protection grounds. If we cannot resolve the objection, the shop may stop using Aurora Automotive, and section 12 applies.

9. Transfers outside Moldova

The records themselves are stored on a server we operate in the Republic of Moldova. Some sub-processors in Annex B are in the United States: email and encrypted backups pass through them. Where the law requires safeguards for such transfers, we rely on the ones each sub-processor provides, including the European Commission’s Standard Contractual Clauses and the EU–US Data Privacy Framework, and on any additional basis the law of the Republic of Moldova requires.

10. Help with people’s requests

Aurora Automotive lets the shop find, correct, export and delete its records itself. If a data subject writes to us about the shop’s records, we pass the request to the shop without undue delay and do not answer it ourselves, unless the shop asks us to. We help the shop, as far as is reasonable, to answer such requests, to secure its records, to assess the impact of its processing, and to consult the supervisory authority.

11. Personal data breaches

If we become aware of a personal data breach affecting the shop’s records, we tell the shop without undue delay, and at the latest within 48 hours. We tell it what we know: what happened, which kinds of data and roughly how many people are affected, the likely consequences, and what we have done and recommend. We add what we learn later as soon as we learn it, and help the shop to meet its own obligations to notify.

12. Return and deletion

When the shop stops using Aurora Automotive, or asks us to:

• on request within 30 days, we give the shop a copy of its records in a common machine-readable format;
• within 30 days after that, or after the request if the shop wants no copy, we delete them;
• copies in backups disappear as the backups expire, within 30 more days. Until then they are used for nothing.

We keep a record only where a law requires us to, and only for as long as it does.

13. Information and audits

We give the shop the information it needs to show that this agreement is kept. The shop, or an independent auditor bound by confidentiality, may audit our compliance at its own cost, with 30 days’ notice, no more than once a year unless a breach or an authority requires more, and without access to other shops’ records. A supervisory authority may audit as the law provides.

14. Liability, term and law

Liability under this agreement follows section 15 of the Terms of Use, except where the law does not allow it to be limited. This agreement lasts as long as we process the shop’s records, and its sections 6, 11, 12 and 13 continue until they are deleted. It is governed by the law of the Republic of Moldova, as the Terms of Use are. We may update it as the Terms of Use describe; a change that reduces the protection of the shop’s records will be announced at least 30 days ahead, and the shop may leave under section 12 instead.

Annex A. Security measures

• Encryption in transit: every connection between a browser and our network is HTTPS.
• Separation of shops: each shop’s records are kept apart in the database by row-level security, enforced by the database itself beside the application’s own checks.
• Access: the shop’s people sign in through Aurora Account with passkeys or one-time codes; there are no passwords. The platform administration requires a passkey confirmed within the last 15 minutes.
• Infrastructure: the web services are reached only through a single web entry point; the databases listen on the server itself and are not reachable from the internet; administrative access to the server is limited to the operator.
• Backups: nightly, encrypted at rest, kept 30 days; the server can add backups but cannot read or delete them.
• Least privilege: each key and credential does one job; deployment keys can only deploy.
• Maintenance: software and dependencies are kept up to date, and changes are tested before they are deployed.

Annex B. Sub-processors

Contact: Roman Zubenco, Republic of Moldova · yafebest@gmail.com