Data Processing Agreement (DPA)

Last updated : 20 September 2026

Purpose

This document sets out the contractual framework applicable to the processing of personal data in connection with the use of the Inclusa service, supplementing our privacy policy. (Privacy policy).

Allocation of roles

For the user's account data (identity, authentication, billing), Inclusa acts as data controller within the meaning of the FADP and the GDPR, under the terms described in our privacy policy.

For data contained in the web pages submitted for analysis (scan data), the content and purpose of collection of which from the user's own site visitors is determined solely by the user, Inclusa acts as processor on behalf of the user, who remains the sole controller of that data.

Nature, duration and purpose of processing carried out as processor

Inclusa processes technical excerpts from the public pages of the user's site strictly for the purpose of producing the requested accessibility diagnosis, for the duration of the subscription and then until purged in accordance with the terms described in our privacy policy.

Sub-processors

Inclusa uses Infomaniak SA (Switzerland) as a sub-processor for hosting the infrastructure and data. The user is informed of any change of sub-processor that has a significant impact on the processing of their data.

Security measures

Inclusa implements the security measures described in our privacy policy (encryption at rest, two-factor authentication, per-account data isolation) and undertakes to maintain a level of security appropriate to the identified risks.

Inclusa's obligations

• process data only on the user's documented instructions, within the limits of the subscribed service;
• ensure the confidentiality of the data processed by any person authorised to access it;
• notify the user without undue delay in the event of a data breach concerning them;
• provide reasonable assistance to the user in responding to requests from data subjects relating to data processed on their behalf.

Signed document

A signed version of this data processing agreement can be provided on request to business customers who need one, through our contact form. (our contact form).

Applicable law

This agreement is governed by Swiss law and shall be interpreted consistently with our terms of use.