Data Processing Agreement

Effective Date: 23 June 2025

1

Introduction

This Data Processing Agreement (“Agreement”) is entered into between:

(1) PE Merkulov, with a registered website at readabler.com , hereinafter referred to as the “Processor”,
and
(2) The customer using the Readabler WordPress plugin, hereinafter referred to as the “Controller”.

This Agreement supplements the Terms of Service and governs the processing of personal data by the Processor on behalf of the Controller pursuant to the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

2

Subject Matter of Processing

This Agreement applies to the processing of personal data by the Processor in connection with the use and licensing of the Readabler WordPress plugin (the “Plugin”).

3

Nature and Purpose of Processing

The Processor processes personal data for the sole purpose of:

  • Activating the Readabler plugin via license key
  • Verifying the legitimacy of the license
  • Enabling automatic updates and ongoing support for the plugin

No personal data is processed unless the plugin is activated with a valid license key.

4

Types of Personal Data Processed

Upon activation, the following data may be collected:

  • Website domain name
  • Administrator email address (as configured in the WordPress dashboard)
  • License key

This data is securely transmitted to and stored on the Processor’s update server.

5

Duration of Processing

Personal data is processed:

  • Only for the duration of the plugin’s active installation
  • Automatically deleted 90 days after the plugin is removed or deactivated

License verification requests are made once every 14 days during the active period.

6

Obligations of the Processor

The Processor agrees to:

  • Process personal data solely on documented instructions from the Controller
  • Ensure data confidentiality, security, and access control
  • Protect data using appropriate technical and organizational measures
  • Refrain from sharing or selling data to third parties
  • Notify the Controller of any data breach without undue delay

7

Sub-Processors

The Processor does not share the collected data with sub-processors. However, the Plugin may utilize browser-based services for accessibility functionality, which may process data independently:

  • Google TTS (Text-to-Speech)
  • Browser-native Speech Recognition APIs

These services operate via the end-user’s browser and are subject to their respective privacy policies.

8

International Transfers

The Processor stores data on servers located within the European Economic Area (EEA). No international transfers of personal data are performed by the Processor.

9

Assistance with Data Subject Rights

Since only minimal data is collected for licensing purposes, the Processor does not support direct data access or erasure requests. However:

  • Data is automatically deleted 90 days after plugin deactivation
  • No profiling or automated decision-making is conducted

10

Data Retention

Data Type Retention Period
Email and domain (on activation) 90 days after plugin removal/deactivation
Cookie (mdp- readabler- hide) Stored in the browser indefinitely (local only)

 

11

Security Measures

The Processor implements industry-standard security practices, including:

  • Encrypted transmission of data via HTTPS
  • Secure storage on dedicated servers
  • Limited access controls

12

Termination

Upon termination of plugin usage, the Processor will delete or anonymize all associated data within 90 days, unless retention is required by law.

13

Liability

Each party shall be responsible for its own compliance with applicable data protection laws. The Processor’s total liability shall be limited as described in the general Terms of Service.

14

Contact Information

For all data protection-related inquiries, the Processor can be contacted at:
Name: PE Merkulov
Email: [email protected]
Website: readabler.com

This Agreement is effective from the date the Controller activates the Readabler plugin and shall remain in effect as long as personal data is processed.