Data Processing Agreement

Effective date: 2026-09-10 · Last updated: 2026-10-12

This Data Processing Agreement ("DPA") forms part of, and supplements, the Terms of Use for Arkidor for Confluence (the "App"). It applies where Knaap processes personal data on behalf of a customer in connection with the App.

How this DPA applies. Arkidor for Confluence is obtained through the Atlassian Marketplace, where Atlassian acts as merchant of record for the purchase. Atlassian's own data processing terms govern Atlassian's processing of your data. This DPA governs Knaap's processing of personal data as described below, and applies automatically to your use of the App — no separate signature is required for it to take effect.

1. Parties and roles

This DPA is between:

• Knaap (owned by Arthur van der Knaap), Itäinentie 50, 06100 Porvoo, Finland — the Processor; and
• the organisation that installs and uses Arkidor for Confluence — the Controller ("Customer").

For the processing described in §3, the Customer is the controller and Knaap is the processor within the meaning of GDPR Articles 4(7)–(8) and 28.

2. Subject matter, duration, nature and purpose

• Subject matter: processing of personal data contained in or associated with ArchiMate models the Customer creates with the App.
• Duration: for the term of the App installation/subscription and as required to complete return or deletion under §9.
• Nature and purpose: storing, retrieving, and rendering models as attachments inside the Customer's Confluence tenant, and resolving author names for version history, solely to provide the App's functionality on the Customer's documented instructions.

3. Categories of data subjects and personal data

No special-category data is required or requested by the App. The Customer must not use free-text model content to store special-category or otherwise sensitive personal data beyond what the Customer's own lawful basis permits.

4. Processor obligations (Article 28(3))

Knaap shall:

1. Documented instructions — process personal data only on the Customer's documented instructions (including as expressed through use of the App and this DPA), including as to transfers, unless required by EU or Member-State law (in which case Knaap will inform the Customer unless legally prohibited).
2. Confidentiality — ensure persons authorised to process the data are under an appropriate duty of confidentiality.
3. Security — implement appropriate technical and organisational measures under Article 32 (see §5).
4. Sub-processors — engage sub-processors only under §6.
5. Data-subject rights — assist the Customer, insofar as possible and taking into account the nature of the processing, in responding to data-subject requests. Because model data resides in the Customer's own Confluence tenant, the Customer can action most requests directly in Confluence; Knaap will assist for anything specific to the App.
6. Assistance — assist the Customer with security, breach notification, DPIA, and prior-consultation obligations (Articles 32–36), taking into account the information available to Knaap.
7. Return/deletion — at the Customer's choice, delete or return personal data at the end of provision (see §9).
8. Audit — make available information necessary to demonstrate compliance with Article 28 and allow for and contribute to audits, subject to reasonable confidentiality and notice terms.

Knaap shall inform the Customer if, in its opinion, an instruction infringes the GDPR or other data-protection law.

5. Security measures (Article 32)

Taking into account the state of the art and the nature of processing, measures include:

• Model content and tenant data remain within the Customer's Confluence tenant; Knaap operates no separate database of Customer model content.
• Writes are performed under the acting user's own Confluence session, so Confluence's native authentication and permission model governs access.
• Least-privilege Forge scopes; the app runs on Atlassian's Forge platform with its platform controls.
• Error telemetry is content-scrubbed on the user's device before sending (sendDefaultPii: false, client-side stripping of message text and URLs), designed so that model content and page titles are not exported to Sentry. This scrubbing is a best-effort control, not an absolute guarantee; technical identifiers such as page, space or model IDs may appear in diagnostic messages.
• The Customer administers Confluence-level access controls, restrictions, and retention.

6. Sub-processors

The Customer provides general authorisation for Knaap to engage the sub-processors listed on our sub-processors page. For the processor activity governed by this DPA (in-tenant model and user data), the relevant sub-processor is Atlassian (Forge platform and storage). Sentry (error telemetry) and AWS (support communications and the feedback board) relate to Knaap's own controller-side activities described in the Privacy Policy and are listed for transparency. Knaap will:

• impose data-protection obligations on each sub-processor substantially equivalent to this DPA;
• remain liable for a sub-processor's performance of its data-protection obligations; and
• give the Customer prior notice of any intended addition or replacement, allowing a reasonable period to object on legitimate data-protection grounds.

7. International transfers

Error telemetry is directed to the EU region, and all Knaap-operated support infrastructure is in the EU. Model content resides in the Customer's tenant subject to Atlassian's data-residency configuration. Where any transfer of personal data outside the EEA occurs through a sub-processor, it is carried out under an appropriate Chapter V mechanism (for example, Standard Contractual Clauses), as referenced on the sub-processors page.

8. Personal data breach

Knaap will notify the Customer without undue delay after becoming aware of a personal data breach affecting Customer personal data processed under this DPA, and will provide the information reasonably available to assist the Customer's Article 33/34 obligations.

9. Return and deletion

Because model attachments are stored in and owned by the Customer's Confluence tenant, they remain with the Customer on uninstall by default (they are not deleted by uninstalling the App). On the Customer's written request, Knaap will delete or return any Customer personal data within Knaap's control and delete existing copies unless retention is required by law.

10. Liability, order of precedence, governing law

• Liability under this DPA is subject to the limitations in the Terms of Use (§9), to the extent permitted by law.
• In case of conflict on data-protection matters, this DPA prevails over the Terms of Use; Atlassian's platform and billing terms govern platform and billing matters.
• Governed by the laws of Finland.

11. Contact

To request a counter-signed copy, raise a data-protection question, or exercise audit rights: support@arkidor.io.

Knaap · Itäinentie 50 · 06100 Porvoo · Finland