LISTENING_COPYDATA PROCESSING AGREEMENT

Data Processing Agreement

Last updated 25 July 2026

This Data Processing Agreement ("DPA") forms part of the Terms between you (the "Controller") and Listening Copy (the "Processor") and applies where we process personal data on your behalf under the EU/EEA and UK GDPR. If you are a business (for example a label or studio handling other people's data), this is the agreement your DPO is looking for. For a countersigned copy, email privacy@listeningcopy.com.

1. Roles & scope

You are the Controller of the personal data you upload and enter (recipient names, emails, phone numbers, and the audio itself). We are the Processor, processing that data only to provide the Service and only on your documented instructions (your use of the Service being those instructions). For your own account data, we are the Controller. See the Privacy Policy.

2. Our obligations

  • Process personal data only on your instructions and for the Service.
  • Ensure people authorised to process it are bound by confidentiality.
  • Apply appropriate technical and organisational security (encryption in transit, hashed credentials, access controls).
  • Assist you, so far as possible, with data-subject requests and with your security, breach- notification, and impact-assessment obligations.
  • Notify you without undue delay after becoming aware of a personal-data breach affecting your data.
  • On termination, delete or return your personal data, save for limited retention required by law.
  • Make available the information needed to demonstrate compliance and allow for reasonable audits.

3. Sub-processors

You authorise us to engage the sub-processors below to provide the Service. We remain responsible for their performance and will give notice of intended changes so you may object.

CloudflareObject storage (R2), CDN, email routingEU / global
SupabaseManaged Postgres databaseEU (Frankfurt)
HetznerApplication hostingEU (Germany)
ResendTransactional emailGlobal
Twilio / VonageSMS deliveryGlobal
PolarPayments & billing (merchant of record)Global
PostHog · SentryProduct analytics · error monitoringEU

4. International transfers

Where a sub-processor processes data outside the EEA/UK, that transfer is covered by an appropriate safeguard (such as the EU Standard Contractual Clauses) offered by that provider.

5. Liability & term

This DPA is subject to the limitation of liability in the Terms. It remains in force for as long as we process personal data on your behalf.


Listening Copy is a service provided and operated by Berg Capital ehf., a company registered in Iceland.

Operating legal entity
Berg Capital ehf.
Company registration (kennitala)
480715-0980
VAT number
IS4807150980
Registered address
Bollagörðum 18, 170 Seltjarnarnes, Iceland
Contact email
bergur@listeningcopy.com

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