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Legal

Data Processing Agreement

This Data Processing Agreement (DPA) pursuant to Art. 28 GDPR applies to all customers of Bearing who process personal data of their users or employees through the Bearing platform.

1. Parties

Controller: The respective customer operating a Bearing account and commissioning the processing of personal data.

Processor: Felix Winkel, SW Labs (Kleingewerbe), reachable at .

2. Subject Matter and Purpose

The Processor processes personal data on behalf of the Controller to provide the Bearing platform. Processing includes storage and analysis of user activity and preferences to generate personalised intelligence briefings.

3. Categories of Personal Data

The following categories of personal data are processed:

  • Account data (email address, name)
  • Usage data (platform interactions)
  • Context data (industry, interests, preferences)
  • Technical data (IP address, timestamps)

4. Data Subjects

Users of the Controller who access a Bearing account, and potentially employees of the Controller.

5. Processor Obligations

The Processor undertakes to:

  • Process data only on documented instructions from the Controller
  • Ensure confidentiality of the data
  • Implement all required technical and organisational measures (TOMs) pursuant to Art. 32 GDPR
  • Not engage sub-processors without prior authorisation
  • Assist the Controller in fulfilling data subject requests
  • Delete or return all data upon termination of the contract

6. Hosting and Sub-processors

The platform is operated on EU infrastructure. The marketing website is served via Cloudflare Pages (USA); Cloudflare processes technically necessary connection data in accordance with its own privacy policy.

An up-to-date list of sub-processors is available on request at .

7. Technical and Organisational Measures

The current TOMs are available from the Processor upon request. They include, among other things, encryption of data in transit and at rest, access controls, and regular security reviews.

8. Contact for DPA Requests

To obtain a signed DPA or for questions about data processing, please contact: .

9. Last Updated

April 2026

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