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MileEngine
Draft – legal review pending

Data processing agreement (DPA)

Version: 1 November 2026

This agreement applies between the customer as controller and OnlineBuilders LLC as processor. It forms part of the subscription to MileEngine · Werkstatt-Cockpit and applies as long as we process personal data on behalf of the customer.

1. Subject matter, nature and purpose

We operate the Werkstatt-Cockpit software for the customer: storing, synchronising, displaying, backing up and deleting the data that the customer and its employees record or import. The purpose is organising and documenting work in the workshop.

2. Data subjects and types of data

  • Employees of the customer: name, initials, role, login data, clock times, sign-offs, qualifications and approvals, photos taken during work.
  • Customers of the customer: name, customer number, vehicle data, configuration.
  • Contacts at suppliers and partners: name, company, contact details.

Special categories of data (Art. 9 GDPR) are not intended.

3. Instructions

We only process the data on documented instructions from the customer. The instructions follow from this agreement, the settings in the software and communication by email. If we consider an instruction unlawful, we inform the customer without delay.

4. Confidentiality

Persons with access to the data are bound to confidentiality. Support access only takes place on request or with the customer's approval and is logged.

5. Technical and organisational measures

We take the measures required by Art. 32 GDPR, described in the annex. We may adapt them as long as the level of protection does not decrease.

6. Sub-processors

The customer agrees to the use of the following sub-processors:

CompanyServicePlace of processing
Hetzner Online GmbH, Gunzenhausen, GermanyData centre: servers, database, file storage, backupsGermany
Cloudflare, Inc., San Francisco, USADNS, TLS, attack protection, email forwardingworldwide (EU-US DPF, standard contractual clauses)
Mailgun Technologies, Inc., San Antonio, USASending system emailsEU region (standard contractual clauses)

We operate error monitoring (GlitchTip) ourselves on the servers at Hetzner; there is no further sub-processor for it. We announce new or changed sub-processors at least four weeks in advance by email. The customer may object for good cause; if no solution is possible, the customer may terminate the contract with effect from the change.

7. Assistance

We assist the customer with requests from data subjects (access, rectification, erasure, export), with data protection impact assessments and with notifications to authorities, insofar as our processing is concerned.

8. Personal data breaches

We report personal data breaches to the customer without undue delay, at the latest within 48 hours of becoming aware, with the information under Art. 33(3) GDPR as far as known.

9. Deletion and return

After the end of the contract the customer can export its data for 30 days. We then delete it. Backups are overwritten within a further 30 days.

10. Evidence and audits

We provide the customer with the information needed to demonstrate compliance with these obligations and allow audits after reasonable notice, usually by providing reports and certificates.

11. Third countries

Data is stored in Germany. Access from the USA (seat of OnlineBuilders LLC) and transfers to sub-processors outside the EU/EEA and Switzerland only take place with appropriate safeguards, in particular standard contractual clauses.

Annex: technical and organisational measures

  • Physical access: Hetzner Online GmbH data centres in Germany with access control, video surveillance and ISO/IEC 27001 certification.
  • System access: server access only with keys and two-factor authentication, platform administration only with two-factor authentication (TOTP), workshop PINs stored only as hashes.
  • Data access: roles and permissions in the app; personnel data only for team leads and management, never on workshop tablets.
  • Separation: tenant separation in the database itself (row-level security), not only in the application.
  • Transfer: transmission only encrypted (TLS 1.2 or higher), encrypted backups.
  • Input control: changes are logged as events that are only appended and never overwritten; support access is logged.
  • Availability: daily backups, regular restore tests, monitoring and error reports; apps keep working offline during outages.
  • Review: updates only after automated tests, dependencies updated regularly, measures reviewed yearly.