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Apnotic, LLC Data Processing Agreement

Thank you for using Password Pusher by Apnotic, LLC!

Apnotic, LLC is a US based company but offers an EU data region for better GDPR compliance. Apnotic's EU data center is located in Amsterdam, Netherlands. Processing and storing data in a secure, fair, and transparent way is extremely important to us.

This Data Processing Agreement (“DPA”) is an addendum to the Terms of Service between Apnotic, LLC and the customer.

If you are accepting this DPA on behalf of your customer, you warrant that: (a) you have full legal authority to bind your customer to this DPA; (b) you have read and understand this DPA; and (c) you agree, on behalf of your customer, to this DPA.

These service terms incorporate the Apnotic, LLC Data Processing Agreement” (“DPA”), when the General Data Protection regulation (“GDPR”) applies to your use of Apnotic, LLC services as defined in the DPA. We protect and secure your data to the high standards set out in the agreement.

Definitions

  • “You” or “customer” refers to the company or organization that signs up to use Password Pusher in the EU data region.
  • “Apnotic” refers to Apnotic, LLC.
  • “Password Pusher” refers to the service created and hosted by Apnotic, LLC, available at https://eu.pwpush.com, which is being used by the customer.
  • “Digital Ocean” refers to the cloud infrastructure provider used by Apnotic, LLC to host and manage data storage and databases for the Password Pusher service.
  • “Push” refers to a unique, self-deleting, one-time URL generated by the Password Pusher service for securely sharing sensitive information, such as passwords or secrets, with designated recipients.
  • “Request” refers to a one-time, self-deleting secure upload URL provided by the Password Pusher service, allowing a user to submit sensitive information to be stored as a push.
  • In the course of providing the Password Pusher service to customer pursuant to the agreement, Apnotic, LLC may process data on behalf of customer.
  • In this Data Processing Agreement (“DPA”), “Data Protection Legislation” means the General Data Protection Regulation (Regulation (EU) 2016/279), and all other applicable laws relating to processing of data and privacy that may exist in any relevant jurisdiction.
  • “data controller”, “data processor”, “data subject”, “personal data” and “processing” shall be interpreted in accordance with applicable Data Protection Legislation.
  • The parties agree that customer is the data controller and that Apnotic, LLC is its data processor in relation to data that is processed in the course of providing the service.

Privacy and security of your data

We take many measures to protect and secure your data through backups, redundancies, and encryption. When you use our service, Apnotic will collect information provided to Password Pusher through registration, subscriptions, pushes and requests.

You entrust us with your data and we take that trust to heart. You agree that Apnotic may process your data as described in our data policy and for no other purpose. We do our best to deserve that trust by being open about who we are, how we work, and keeping an open door to your feedback.

You own all right, title, and interest to your data. We obtain no rights from you to your data. When using Password Pusher, you 100% own and control all of your data. We don’t sell or share your data to any third-parties.

We minimize data collection in general and aim to hold data provided in pushes and requests for as little time as possible; however, the retention period is ultimately determined by the expiration limits set by the customer.

You can find more information about our processing of your data and what types/categories of data we collect on your behalf in our publicly available privacy policy.

Organizational and technical security measures

All of the data that we host is kept fully secured, encrypted and hosted in the Netherlands. This ensures that all of the data is being covered by the European Union’s strict laws on data privacy.

For encryption, we use https in transit and the AES-GCM algorithm with 256-bit keys to store push and request contents in the database. Further, the hosting provider Digital Ocean encrypts data at reset using:

  • Spaces (file storage): Data at rest is encrypted (AES-256, industry standard).
  • Managed Databases: Data at rest is encrypted with LUKS (AES-XTS-PLAIN64:SHA256, 512-bit key); backups use AES-256-CTR with HMAC-SHA256 and RSA-encrypted keys.

In addition to this, we use strict firewall rules and private networking.

Password Pusher is largely open source software which means that our source code is available and accessible on GitHub so anyone can check it out and audit it. You can read it, inspect it and review it to understand how it works and to ensure it keeps the data private and secure.

With a long history dating back to its inception in 2011 and more than 2,500 GitHub stars, there are a lot of eyes on our code. This transparency and openness, built over many years, means that open source products like Password Pusher can be more trustworthy than proprietary and closed source products.

Our software is updated several times per week and we also have a way for people to report any security vulnerabilities.

A more detailed overview about our security practices can be found on https://docs.pwpush.com/docs/security/

Processor’s obligations with respect to the controller

  • Apnotic, LLC will process data only in accordance with instructions from customer through the settings of the service, i.e. (a) to operate, maintain and support the infrastructure used to provide the service; (b) to comply with customer’s instructions and processing instructions in their use, management and administration of the service; (c) as otherwise instructed through settings of the service. Apnotic, LLC will only process data in accordance with the agreement.
  • Apnotic, LLC shall notify customer without undue delay if, in Apnotic’s opinion, an instruction for the processing of data given by customer infringes applicable Data Protection Legislation.
  • Apnotic, LLC shall guarantee the confidentiality of data processed hereunder.
  • We as humans can access your data to help you with support requests you make and to maintain and safeguard Apnotic, LLC to ensure the security of your data and the service as a whole. Apnotic, LLC shall ensure that all Apnotic, LLC personnel required to access the data are trained in GDPR and data privacy, informed of the confidential nature of the data and comply with the obligations sets out in this agreement.
  • Under no circumstances will Apnotic or any of its employees directly access the sensitive payload of a push or request unless compelled to do so by a valid legal order. It is Apnotic’s internal policy to never access the sensitive content of pushes and requests under any circumstances, including when requested by the customer.
  • Apnotic, LLC shall implement and maintain appropriate technical and organisational security measures designed to protect the data against unauthorised or unlawful processing and against accidental loss, destruction, damage, theft, alteration or disclosure. These measures shall be appropriate to the harm which might result from any unauthorised or unlawful processing, accidental loss, destruction, damage or theft of the data and having regard to the nature of the data which is to be protected.
  • We do work with sub-processors. With each vendor, we assess their commitment to privacy and maintain a data processing agreement with them that include the controller-processor Standard Contractual Clauses. Any such subcontractors will be permitted to process data only to deliver the services Apnotic, LLC has retained them to provide, and they shall be prohibited from using data for any other purpose. Apnotic, LLC shall notify the controller when modifying the list of subprocessors using our in-app notifications, email and/or blog. The controller is able to legitimately object and may terminate the agreement.
  • You can find the list of cloud services and third party services that we use in our privacy policy.
  • If Apnotic, LLC becomes aware of any accidental, unauthorised or unlawful security breach, destruction, loss, alteration, or disclosure of the personal data that is processed by Apnotic, LLC in the course of providing the service, it shall without undue delay (not later than 48 hours after having become aware of it), notify customer by email and provide customer with a description of the incident as well as periodic updates to information about the incident, including its impact on customer content. Apnotic, LLC shall additionally take action to investigate the incident and reasonably prevent or mitigate the effects of the incident.
  • Apnotic, LLC shall not on its own authority rectify, erase or restrict the processing of data that is being processed on behalf of the controller (unless this is required by law or the Processor Terms of Service), but shall only do so on documented instructions from the controller and in accordance to the data retention rules associated to the controller subscription plan.
  • Apnotic, LLC shall assist the controller in complying with the obligations concerning the security of personal data. Apnotic will also provide assistance to the controller for DPIAs. Where a data subject asserts their rights as a data subject, this request will be forwarded to the controller without delay.

How we handle delete instructions

You can choose to delete your account and delete your data at any time. We provide simple no-questions-asked deletion.

All your data will be permanently deleted immediately when you delete your Password Pusher account. We cannot recover this information once it has been permanently deleted.

Customer undertakings and Apnotic, LLC assistance

  • Customer warrants that it has all necessary rights to provide to Apnotic, LLC the data for processing in connection with the provision of the Apnotic, LLC Services.
  • Customer shall comply at all times with Data Protection Legislations in respect of all data it provided to Apnotic, LLC pursuant to the Agreement.
  • Customer understands, as a controller, that it is responsible (as between customer and Apnotic, LLC) for:
  1. determining the lawfulness of any processing, performing any required data protection impact assessments, and accounting to regulators and individuals, as may be needed;
  2. providing relevant privacy notices to data subjects as may be required in your jurisdiction;
  3. implementing your own appropriate technical and organizational measures to ensure and demonstrate processing in accord with this DPA;
  4. notifying any relevant regulators or authorities of any incident as may be required by law in your jurisdiction.

Liability and Indemnity

Each party indemnifies the other and holds them harmless against all claims, actions, third party claims, losses, damages and expenses incurred by the indemnified party and arising directly or indirectly out of or in connection with a breach of this DPA.

Duration and Termination

  • The DPA is effective as of July 16, 2025 and replaces and supersedes any previously agreed data processing agreement between you and Apnotic, LLC relating to the GDPR.
  • Termination or expiration of this DPA shall not discharge the parties from the confidentiality obligations herein.

Are customers required to sign the Apnotic, LLC DPA?

In order to use our products and services, you need to accept our DPA. By using our product you are agreeing to our terms of service, and you are automatically accepting our DPA and do not need to sign a separate document. We provide the same privacy rights and protection to all customers.

Can a customer share the Apnotic, LLC DPA with its customers?

Yes. The DPA is a publicly available document and customers who wish to share it with their customers to confirm our security measures and other terms may feel free to do so.

Do customers need to notify anyone upon accepting our DPA?

No. You are not required to notify us or any third party upon accepting our DPA though, as mentioned above, you are free to do so.

Contact Us

If you have a question about the Data Processing Agreement (DPA), please contact us.

If you have any questions or concerns regarding your information and personal data, please contact us at privacy@pwpush.com.

Last updated: July 16, 2025

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