Privacy overview

At Gumlet, we take your privacy very seriously and implement all necessary measures to ensure your data stays safe and private.



Database Location
๐Ÿ‡บ๐Ÿ‡ธ USA
Subprocessors Data Location
๐Ÿ‡บ๐Ÿ‡ธ USA
๐Ÿ‡ณ๐Ÿ‡ฑ The Netherlands
๐Ÿ‡ช๐Ÿ‡ช Estonia
๐Ÿ‡ง๐Ÿ‡ช Belgium
๐Ÿ‡จ๐Ÿ‡ฆ Canada
๐Ÿ‡ฆ๐Ÿ‡บ Australia
๐Ÿ‡ช๐Ÿ‡บ European Union
Our Privacy Policy will soon be available here.

Privacy Policy

Last update: May 31, 2023

1. Introduction

This Privacy Policy applies to the website (hereinafter the โ€œwebsiteโ€) published by the company Gumlet Pte. Ltd. (hereinafter โ€œGumletโ€ or โ€œweโ€) and its other services and products for which personal data is being communicated to Gumlet.

Please read this Privacy Policy carefully as it explains how Gumlet uses your personal data and how to exercise your rights. This Privacy Policy supplements the Terms & Conditions or any documents or notices that may refer to this Privacy Policy.

Should you have any questions, you may directly contact Gumlet by sending an email to

2. Definitions

DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).


USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

โ€COOKIES are small files stored on your device (computer or mobile device).

โ€DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.


DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.


DATA SUBJECT is any living individual who is the subject of Personal Data.


THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. Legal context

We abide by the recommendations of the relevant authorities and have put in place an organization to ensure our compliance with the regulatory framework established by the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and any other laws or regulations relating to personal information that apply to us.

4. What is our role?

Under the GDPR, we are considered as a data controller. It means that we set the whys and hows we process your personal information. For example, when you are visiting our website, we are in charge of determining the purposes and the means that are necessary to administer, operate and manage our usersโ€™ personal information that we collect from it.

Depending on the activity we perform on your data, we may also be considered as a data processor. This means that you are our customerโ€™s end user and that we are processing your data under the instructions of our customer considered as a data controller. In this case, the data controller sets the purposes and means of the processing activity, and we abide and deliver our service in regards to these.

5. What kind of personal information do we process?

We only collect and process personal information that is relevant and adequate. We give special attention to its accuracy and updates when needed. Personal information includes in particular:

Type of dataExamples of data
Identification datae.g. first name, last name, picture, birth date, etc.
Professional datae.g. company name, skills, job title, diplomas, etc.
Connection datae.g. IP address, logs, terminal and connection identifiers, timestamp, etc.
Contact datae.g. email address, phone number, postal address, ect.
Economic and financial datae.g. income, financial situation, tax situation, banking details, etc.
Internet datae.g. cookies, tracers, navigation data, audience metrics, etc.
Location datae.g. movements, GPS data, GSM, etc.
Images & video datae.g. video footage or photography

The collection of this information may at times be mandatory in order to provide our service, other times optional to enhance your experience and left to your good will. Mandatory information will be identified as such when we collect your data. Know that if you refuse to provide it, Gumlet wonโ€™t be able to provide you with its utmost service and you will unfortunately experience inconveniences.

6. When do we collect your personal information?

We collect your personal information on various occasions.

Sign up formIndividual signed up online
Billing formIndividual filled in a payment checkout
Chat & Email conversationIndividual contacted us directly by mail
Online or paper formIndividual filled in a form
Website or software visitIndividual browsed our website or our solution
Video recordingIndividual is recorded on camera

7. How do we use your personal information?

Your personal information will never be processed for incompatible purposes regarding why it was first collected. We only collect and process personal information for specified, explicit and legitimate purposes, like:

Processing ActivitiesPurposesLegal basis
Creation and management of user accountTo grant individuals access to the service, administer and manage accountsContractual duties, Legitimate interest
Payment & billing managementTo process money transactionsContractual duties
Marketing communicationTo send marketing communications about updates and promotions regarding the serviceLegitimate interest, Consent
Electronic signature managementTo digitally seal contracts and legal documentsLegitimate interest
Accounting managementTo comply with accounting and tax obligationsLegal and regulatory obligations
Website audience measurementTo gather analytics on the website trafficConsent
Internal communications & collaborationTo collaborate internally on the company's projectsLegitimate interest

In order to comply with the principle of lawfulness, the legal bases for each data processing is determined carefully and on a case-by-case basis in accordance with the list provided by Article 6 of the GDPR.

We do not process your data or use automated decision making without your knowledge, nor do we sell or rent your personal information without your explicit consent.

8. Who can access your personal information?

Recipients to whom we disclose your personal information are carefully chosen by us. They receive data for legitimate purposes, especially when it comes to pursuing our business activity and providing a qualitative service:

SubprocessorService provided
Twilio dba SegmentInfrastructure and developer tools
Mixpanel IncProduct analytics
PlausiblePrivacy-friendly analytics
Zoho Books
Alpha OS
Customer.ioCustomer interactions
DocuSignE-signature platform

Certain data recipients are considered our data processors in accordance with Article 28 of the GDPR, which means we review how they handle personal information and make sure they put in place appropriate guarantees to protect it.

Other recipients are considered authorized third parties in accordance with Article 4 of the GDPR, which means we have to communicate your personal information to them to comply with applicable legal obligations, lawful requests and processes (subpoenas, requests from government or tax authorities, etc.).

9. Where do we transfer your personal information?

As far as possible, your personal information is processed within the European Union. However, some of our service providers may be located in another country of which you are a resident or pursuing their activity outside of the European Union.

When we transfer your personal information to a recipient outside the European Union, we take care of putting in place sufficient guarantees in accordance with the list provided by Articles 44 to 50 of the GDPR, whether it is having it stored in a country with an adequate privacy protection or contracting Data Protection Agreements to ensure your personal information is protected.

SubprocessorLocationAdopted safeguard
Twilio dba SegmentUSAData Processing Agreement

10. How long do we store your personal information?

As a general rule when we are considered a data controller by the GDPR, retention periods of your personal information are determined according to the purposes for which we collected it and our legal obligations.

Regarding our activities as a data processor, we retain our customersโ€™ end users personal information as long as required by our terms and conditions and the pursuing of the service our customersโ€™ subscribed to.

When these purposes are fulfilled or when you ask us, your personal information is archived, erased or anonymized.

11. How do we protect your personal information?

We care deeply about the safety of your personal information and that is why we put in place adequate technical and organizational security measures to preserve its confidentiality, integrity and availability.

We take into account the risks for your rights and freedoms and therefore follow with great care the recommendations of the competent authorities regarding security.

12. What are your rights and how to exercise them?

In accordance with Articles 12 to 23 of GDPR, you have rights over your personal information that we are committed to respect:

  • you can request access to your personal information and a copy of it
  • you can ask us to modify your personal information if you consider it obsolete, inaccurate or incomplete.
  • you can object to the processing of your personal information if based on our legitimate interest in certain circumstances.
  • you can request to restrict the processing during a limited period of time, in certain circumstances.
  • you can opt-out from a consent already given, without this withdrawal affecting the lawfulness of the processing operations already carried out.
  • when technically feasible, you can ask us to send you the personal information you provided us or that we communicate it to a third party.
  • you can ask us to delete your personal information if it meets legal grounds for which it is applicable.

These rights can be exercised directly and at any time by sending an email to or on our Data Requests page. In the case you are our customerโ€™s end user, please take into consideration that this request will be forwarded and must be answered directly by them.

13. Children's privacy

Our Services are not intended for use by children under the age of 13 (" Children").

We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

14. Policy changes

This Privacy Policy may be modified in the future to keep it updated with legal jurisprudence and evolution. You'll be informed either by a special mention on this page or by a personalized warning, by email for instance.

15. Contact us

If you have any questions about this Privacy Policy, please contact us via email at

We dont use cookies to provide our service, we prefer to eat them ๐Ÿช

Cookie Policy

Last update:
May 31, 2023
Part of the provision of our service and this website relies on the collection of cookies. Depending on their use, they may be considered essential or subject to your explicit consent.

What is a cookie?

A cookie is a small text file that may be deposited and saved on the hard drive of your device (computer, tablet, smartphone, etc.) when you visit our website. It allows us or third parties to identify the device on which it has been saved and to keep record of certain information relating to your journey in order, for instance, to simplify your visit on our website, to secure your connection or to adapt the content of a page to your interests.

What types of cookies are collected?

Essential cookies
These cookies are strictly necessary to provide you with our website and use its functionalities. If you choose to disable these cookies via your internet browser, access and/or use of our website may be altered.
Analytics and Performance Cookies
These cookies are useful to measure the audience and performance of our website and help us understand how visitors interact with it.

How to manage cookies?

Your internet browser may allow you to manage your cookie preferences by removing or rejecting them via your browser settings (usually located in "help", โ€œtoolsโ€ or โ€œeditโ€ sections). Remember that if you choose to disable our cookies, you may experience some inconvenience when using our website.


In an effort to be as transparent as possible to our customers, the Subprocessor list includes any third-parties who may have access to your data by utilizing our service. The type of data that the Subprocessor has access to is limited to only what is reasonably necessary to perform the service provided.

Prior to engaging with a Subprocessor, Gumlet performs extensive due diligence, which includes security and legal analysis. Each Subprocessor is subject to contract terms that enforce compliance with applicable data protection laws.

This list is subject to change, as the needs of the business change. For more information, please contact

Gumlet currently uses the following Subprocessors:
Download our Data Processing Agreement
Download as PDF
A Data Processing Agreement, or DPA, is a contract necessary between an organization that provides data and the organization that receives this data to perform a service (hosting, email delivery, video conferencing, payment and billing, data analysis, etc.).
Our DPA will soon be available here.

Data Protection Agreement

This Data Protection Agreement (« Agreement ») is entered into between Gumlet Pte. Ltd. and the undersigned Customer identified in the applicable Appendix I at Controller section and the signature block below (« Customer ») as of the last date beneath Customer’s and Gumlet Pte. Ltd.’s signature blocks below (« Addendum Effective Date »). This Agreement forms part of the agreement between Customer and Gumlet Pte. Ltd. covering Customer’s use of the Services (as defined below).

Clause 1: Purpose and scope 

(a)    The purpose of this Agreement is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

(b)    The controllers and processors listed in Appendix I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679. 

(c)    These Clauses apply to the processing of personal data as specified in Appendix II.

(d)    Appendixes I to III are an integral part of the Clauses.

(e)    These Clauses are without prejudice to obligations to which the Customer is subject by virtue of Regulation (EU) 2016/679. 

(f)    These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679. They are herein completed by Standard Contractual Clauses for personal data transfers outside the European Union/European Economic Area (EU/EEA) if needed.

Clause 2: Invariability of the Clauses 

(a)    The Parties undertake not to modify the Clauses, except for adding information to the Appendixes or updating information in them. 

(b)    This does not prevent the Parties from including these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict  the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3: Interpretation

(a)    Where these Clauses use the terms defined in Regulation (EU) 2016/679, those terms have the same meaning as in that Regulation.

(b)    These Clauses must be read and interpreted in the light of the provisions of Regulation (EU) 2016/679.

(c)    These Clauses are not to be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4: Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses will prevail.

Clause 5: Docking clause

(a)    Any entity that is not a Party to these Clauses may, with the agreement of all the Parties, accede to these Clauses at any time as a controller or a processor by completing the Appendixes and signing Appendix I.

(b)    Once the Appendixes in (a) are completed and signed, the acceding entity will be treated as a Party to these Clauses and have the rights and obligations of a controller or a processor, in accordance with its designation in Appendix I.

(c)    The acceding entity will have no rights or obligations resulting from these Clauses from the period prior to becoming a Party.

Clause 6: Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the Customer, are specified in Appendix II.

Clause 7: Roles of the Parties 

7.1. Instructions

(a)    Gumlet Pte. Ltd. processes personal data only on documented instructions from the Customer, unless required to do so by Union or Member State law to which Gumlet Pte. Ltd. is subject. In this case, Gumlet Pte. Ltd. will inform the Customer of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the Customer throughout the duration of the processing of personal data. These instructions are always to be documented.

(b)    Gumlet Pte. Ltd. immediately informs the Customer if, in Gumlet Pte. Ltd.’s opinion, instructions given by the Customer infringe Regulation (EU) 2016/679 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

Gumlet Pte. Ltd. processes the personal data only for the specific purpose(s) of the processing, as set out in Appendix II, unless it receives further instructions from the Customer.

7.3. Duration of the processing of personal data

Processing by Gumlet Pte. Ltd. only takes place for the duration specified in Appendix II. 

7.4. Security of processing

(a)    Gumlet Pte. Ltd. implements the technical and organizational measures specified in Appendix III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects. 

(b)    No provision of this Agreement includes the right to, and Customer may not, directly or indirectly, enable any person or entity other than authorized users to access or use the Services, or use (or permit others to use) the Services other than as described in the applicable Agreement.

(c)    Gumlet Pte. Ltd. grants access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring the contract. Gumlet Pte. Ltd. ensures that persons authorized to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality. 

7.5. Sensitive data

(a)    If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), Gumlet Pte. Ltd. applies specific restrictions and/or additional safeguards.

(b)    Without limiting its responsibilities under this Agreement, Customer is responsible for ensuring that no sensitive data is submitted to Gumlet Pte. Ltd. when not necessary for the processing activities available in Appendix II.

7.6 Compliance with documented instructions

(a)    The Parties are able to demonstrate compliance with these Clauses.

(b)    Gumlet Pte. Ltd. deals promptly and adequately with inquiries from the Customer about the processing of data in accordance with these Clauses.  

7.7 Audit

(a)    Upon request, Gumlet Pte. Ltd. makes available to the Customer all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679. At the Customer’s request, Gumlet Pte. Ltd. also permits and contributes to audits of the processing activities covered by these Clauses.

(b)    For any intended audit or inspection, the Customer undertakes to notify Gumlet Pte. Ltd. by providing a reasonable prior written notice at least fourteen (14) business days before the audit or the inspection.

(c)    The Customer may choose to conduct the audit by itself or mandate an independent auditor. In deciding on a review or an audit, the Customer may take into account relevant certifications held by Gumlet Pte. Ltd..

(d)    The Parties makes the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.8. General authorization for the use of sub-processors

(a)    Gumlet Pte. Ltd. has the Customer’s general authorization for the engagement of sub-processors from an agreed list available below in Appendix II.

(b)    Gumlet Pte. Ltd. will endeavor to give the Customer written notice of any intended changes of that list through the addition or replacement of sub-processors at least thirty (30) days in advance, thereby giving the Customer fifteen (15) days to object on reasonable grounds to such changes prior to the engagement of the concerned sub-processor(s) by sending an email to

(c)    The Customer acknowledges that certain sub-processors are essential to providing the Services and that objecting to the use of a sub-processor may prevent Gumlet Pte. Ltd. from offering the Services to the Customer. If the Customer does not object to the engagement of a sub-processor in accordance within fifteen (15) days of notice by Gumlet Pte. Ltd., that sub-processor will be deemed an authorised sub-processor for the purposes of this Agreement. 

(d)    Where Gumlet Pte. Ltd. engages a sub-processor for carrying out specific processing activities (on behalf of the Customer), it will do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on Gumlet Pte. Ltd. in accordance with these Clauses. Gumlet Pte. Ltd. will ensure that the sub-processor complies with the obligations to which Gumlet Pte. Ltd. is subject pursuant to these Clauses and to Regulation (EU) 2016/679.

(e)    At the Customer’s request, Gumlet Pte. Ltd. provides a copy of such a sub-processor agreement and any subsequent amendments to the Customer. To the extent necessary to protect business secret or other confidential information, including personal data, Gumlet Pte. Ltd. may redact the text of the agreement prior to sharing the copy.

(f)    Gumlet Pte. Ltd. remains fully responsible to the Customer for the performance of the sub-processor’s obligations in accordance with its contract with Gumlet Pte. Ltd.. Gumlet Pte. Ltd. will notify the Customer of any failure by the sub-processor to fulfill its contractual obligations.

7.9. Personal data transfers outside the EU/EEA

(a)    Any transfer of personal data to a country or an international organization outside the EU/EEA by Gumlet Pte. Ltd. is operated only on the basis of performing the services for and to the Customer or in order to fulfill a specific requirement under Union or Member State law to which Gumlet Pte. Ltd. is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679.

(b)    If the storage and/or processing of Personal Data as described in Appendix II involves a transfer of personal data to Gumlet Pte. Ltd. outside of the EU/EEA, and Regulation (EU) 2016/679 applies to the transfer, then Standard Contractual Clauses for the transfer of personal data to third countries (hereinafter “SCCs”) are to be incorporated into and form a part of this Agreement in accordance.

(c)    The Customer agrees that where Gumlet Pte. Ltd. engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the Customer) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, Gumlet Pte. Ltd. and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by, in particular:

  1. implementing appropriate safeguards such as SCCs adopted by the Commission in accordance with Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those SCCs are met, or

  2. being subject to binding corporate rules in accordance with Article 47 of Regulation (EU) 2016/679, or

  3. ensuring that such transfer is covered by a decision of adequacy by the European Commission in accordance with Article 45 of Regulation (EU) 2016/679, or

  4. complying to the derogations for specific situations in accordance with Article 49 of Regulation (EU) 2016/679.

Clause 8: Assistance to the Customer 

8.1 Data subjects rights

(a)    Gumlet Pte. Ltd. promptly notifies the Customer of any request it has received from the data subject. It will not respond to the request itself, unless authorized to do so by the Customer.

(b)    Gumlet Pte. Ltd. assists the Customer in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), Gumlet Pte. Ltd. complies with the Customer’s instructions.

8.2 Cooperation with the Customer

Gumlet Pte. Ltd. furthermore assists the Customer in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to Gumlet Pte. Ltd.:

(a)    the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;

(b)    the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the Customer to mitigate the risk;

(c)    the obligation to ensure that personal data is accurate and up to date, by informing the Customer without delay if Gumlet Pte. Ltd. becomes aware that the personal data it is processing is inaccurate or has become outdated;

(d)    the obligations under Article 32 Regulation (EU) 2016/679.

Clause 9: Notification of personal data breach

In the event of a personal data breach concerning data processed by Gumlet Pte. Ltd., Gumlet Pte. Ltd. notifies the Customer without undue delay after having become aware of the breach. Such notification shall contain, at least:

(a)    a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b)    the details of a contact point where more information concerning the personal data breach can be obtained;

(c)    its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification will contain the information then available and further information will, as it becomes available, subsequently be provided without undue delay.

Gumlet Pte. Ltd. cooperates with and assists the Customer for the Customer to comply with its obligations under Articles 33 and 34 Regulation (EU) 2016/679, where applicable, taking into account the nature of processing and the information available to Gumlet Pte. Ltd..

Clause 10: Non-compliance with the Clauses and termination

10.1 Suspension of the processing activity

(a)    Without prejudice to any provisions of Regulation (EU) 2016/679, in the event that Gumlet Pte. Ltd. is in breach of its obligations under these Clauses, the Customer may instruct Gumlet Pte. Ltd. to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. Gumlet Pte. Ltd. promptly informs the Customer in case it is unable to comply with these Clauses, for whatever reason.

(b)    The Customer shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

(1)    the processing of personal data by Gumlet Pte. Ltd. has been suspended by the Customer pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;

(2)    Gumlet Pte. Ltd. is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 ; 

(3)    Gumlet Pte. Ltd. fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679.

(c)    Gumlet Pte. Ltd. shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the Customer that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the Customer insists on compliance with the instructions.

10.2 Destruction or return of the Customer’s personal data

Following termination of the Services, Gumlet Pte. Ltd., at the choice of the Customer, deletes all personal data processed on behalf of the Customer and certify to the Customer that it has done so on request, or, returns all the personal data to the Customer and deletes existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, Gumlet Pte. Ltd. shall continue to ensure compliance with these Clauses. 

Appendix I: List of parties

Controller(s): [Identity and contact details of the Customer(s), and, where applicable, of the Customer’s data protection officer]

1. Name: __________

Address: __________

Contact person’s name, position and contact details: __________

Signature: __________

Accession date: __________


1. Name: Gumlet Pte. Ltd.

Address: 20A, Tanjong Pagar Road, 088443 Singapore, Singapore

Contact person’s name, position and contact details: Aditya Patadia, CEO (

Signature: __________

Accession date: __________

Appendix II: Description of the processing

Categories of data subjects whose personal data is processed:

  • Customers
  • Prospects
  • Users
  • Employees
  • Suppliers
  • Contractors

Categories of personal data processed:

  • Identification data
  • Internet data
  • Professional data
  • Connection data
  • Location data
  • Contact data
  • Economic and financial data

Nature of the processing:

  • Marketing communication
  • Website audience measurement
  • Creation and management of user account
  • Payment & billing management
  • Accounting management
  • Electronic signature management

Purpose(s) for which the personal data is processed on behalf of the Customer:

  • To send marketing communications about updates and promotions regarding the service
  • To gather analytics on the website traffic
  • To grant individuals access to the service
  • administer and manage accounts
  • To process money transactions
  • To comply with accounting and tax obligations
  • To digitally seal contracts and legal documents

Duration of the processing:

Processing activityRetention period
Marketing communication
Website audience measurementAs long as necessary for the performance of the service
Creation and management of user account
Payment & billing managementAs long as necessary for the performance of the service
Accounting managementAs long as necessary for the performance of the service
Electronic signature managementAs long as necessary for the performance of the service

For processing by (sub-) processors, also specify subject matter, nature and duration of the processing:

SubprocessorProcessingCountryPrivacy contact
Alpha OS
Twilio dba SegmentInfrastructure and developer
Customer.ioCustomer interactionsUSA,
Mixpanel IncProduct analyticsUSA, The
Zoho Books
DocuSignE-signature platformUSA, Canada, Australia, European

Appendix III: Technical and organizational measures including technical and organizational measures to ensure the security of the data and assistance to the customer

A: Security measures taken by Gumlet Pte. Ltd.

Measures for user identification and authorisation
  • Unique identifier per user
  • Prohibition of shared accounts
  • Strong password policy
  • Logical access restriction
  • SSO authentication
  • Multi-factor authentication
  • Access on a need-to-know basis
  • Regular access review
Measures for ensuring events traceability
  • User access journaling
  • System access & attempts log
  • Security event logging
Measures for certification/assurance of processes and products
  • Software license monitoring
  • Software security updates
  • Risk assessment program
Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services
  • Asset inventory
  • Firewall on internet traffic
  • Logical data segregation
  • Vulnerability monitoring and patching
  • Attack prevention (anti-DDoS, anti-spoofing)
Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident
  • Frequent data backup
  • Backup encryption
  • Disaster recovery plan
Measures of pseudonymisation and encryption of personal data
  • HTTPS encryption in transit
  • TLS 1.2 or 1.3 used in transit
  • AES encryption at rest
Measures for ensuring the continuity of the protection of personal data when transferred to other organizations
  • Security clauses and contractual obligations
    Measures for ensuring physical security of locations at which personal data are processed
    • Physical access control
    • Device encryption
    • Secured paper archiving
    Measures for internal IT and IT security governance and management
    • Security ownership and roles
    • Security policies and procedures
    • Security training
    • Employees confidentiality obligations
    • Employees background check
    Measures for ensuring system configuration, including default configuration
    • Malicious code detection
    • Code review and testing (OWASP)
    • Prohibition of personal data on non-production environment
    • Privacy by design and by default
    Measures for allowing data portability and ensuring erasure
    • Right request management process
    • Reversibility process and clauses
    • Secured data erasure
    • Secured device destruction
    • Issuance of destruction certificate

    Gumlet Pte. Ltd. may update or modify such measures from time to time, provided that such updates and modifications do not materially decrease the overall security of the Service.

    B: Security measures taken by sub-processors

    SubprocessorSecurity commitment
    Alpha OS
    Twilio dba Segment
    Mixpanel Inc
    Zoho Books

    Standard Contractual Clauses

    For the purposes of these Standard Contractual Clauses for the transfer of personal data to third countries pursuant to the European Commission’s decision (EU) 2021/914 of 4 June 2021 (hereinafter “SCCs”) available at, the Customer is the controller of the personal data received and Gumlet Pte. Ltd. is the processor of such data.

    For the purposes of the SCCs, the following shall apply:

    (a)    Module Two (Controller to Processor) will apply;

    (b)    Each Party agrees to be bound by and comply with its obligations in its role as exporter and importer respectively as set out in the SCCs;

    (c)    Clause 7 (Docking clause) shall be deemed as included;

    (d)    Clause 9 (a) (Use of sub-processors): Option 2 “General written authorization” will apply as set out in Clause 7.7 of this Agreement.

    (e)    Clause 11 (Redress: optional clause of redress mechanism before an independent dispute resolution body) shall be deemed as not included;

    (f)    Clause 13 (a) (Supervision): The supervisory authority with responsibility for ensuring compliance by the data exporter with Regulation (EU) 2016/679 as regards the data transfer, as indicated in Annex I.C, shall act as competent supervisory authority;

    (g)    Clause 17 (Governing law): The Parties agree that this shall be the law to which the data exporter is subject.

    (h)    Clause 18 (b) (Choice of forum and jurisdiction): The Parties agree that any dispute between them arising from the SCCs shall be resolved by the courts of the country where the data exporter is established.

    Annex I

    A. List of parties

    Gumlet Pte. Ltd. is the “data importer” and the Customer is the “data exporter” as set out in this Agreement.

    B. Description of transfer

    As described in the Appendix II of this Agreement.

    C. Competent Supervisory Authority

    The SCCs shall be governed by the law of the EU Member State in which the Customer is established.

    Annex II - Technical and organizational measures including technical and organizational measures to ensure the security of the data

    As listed in the Appendix III of this Agreement.

    Annex III – List of sub-processors

    As listed in the Appendix II of this Agreement.

    Data Request Forms

    In accordance with Articles 12 to 23 of GDPR, you have control over your personal data. You can request from us to exercise any right (access, modify or delete) them under a month delay.
    Request access
    Receive a copy of your personal data we process.
    Request rectification
    Obtain the modification of your personal data if it is obsolete, inaccurate or incomplete.
    Object to the processing of your personal data
    You can object to the processing of your personal data for the following reasons:
    Right to restriction of processing
    You can request to restrict the processing during a limited period of time for the following reasons:
    Withdraw consent
    you can opt-out from a consent already given, without this withdrawal affecting the lawfulness of the processing operations already carried out.
    Request erasure
    you can ask us to delete your personal information for the following reasons:
    Request the transfer of your personal data
    when technically feasible, you can request the transmission of your data to a third party. It applies only if it fulfils all the following conditions: