Data Processing Agreement.
GDPR Article 28 / Swiss FADP-compliant DPA between Ruznic Marketing and customers.
1. Purpose
This Data Processing Addendum ("DPA") forms part of the Reality Twin Terms of Service between Ruznic Marketing, Leimgrubstrasse 5, 8340 Hinwil, Switzerland ("Processor") and the customer ("Controller"). It governs the processing of personal data by the Processor on behalf of the Controller.
2. Roles
The Controller determines the purposes and means of processing personal data submitted to the Service. The Processor processes that data only on documented instructions from the Controller.
3. Sub-processors
The current sub-processors used to deliver the Service are listed below. The full, always-current list — including regions and purposes — is maintained on the sub-processors page.
| Sub-processor | Purpose | Region |
|---|---|---|
| Cloudflare | Edge runtime, CDN & DDoS protection | Global edge |
| Supabase | Application database & authentication | EU (Ireland) |
| OpenAI / Anthropic | Foundation-model inference for twin responses | EU / US (opt-in) |
| Resend | Transactional email | EU |
4. International transfers
Cross-border transfers (e.g. to US sub-processors used for model inference) rely on the European Commission's Standard Contractual Clauses and the Swiss FADP addendum, with supplementary measures including encryption in transit (TLS 1.3) and at rest (AES-256).
5. Security
See our Security page for the current state of our controls. SOC 2 and ISO 27001 certifications are on the roadmap, not yet in place.
6. Data subject rights
The Processor assists the Controller in responding to data subject requests within statutory timelines (GDPR / Swiss FADP). Export and deletion are available on request.
7. Notification of changes
We will provide at least 30 days' notice before adding or replacing a sub-processor. Controllers may object in writing during that period.
8. Signature
To execute the DPA, email hello@realitytwin.io with your entity details. We will return a counter-signed copy within two business days.