Parties
Controller: you, our client. Processor: Brainjuice Labs LDA, registered in Portugal, operating the CiteSurge product.
Brainjuice Labs LDA (CiteSurge)Startup Madeira – EV 297
Campus da Penteada
9020-105 Funchal – Madeira
Portugal
Subject and duration
CiteSurge processes personal data only to deliver the services in your statement of work. Processing ends when the engagement ends, unless retention is required by law.
Categories of data and data subjects
- Site analytics: aggregate visitor behavior on your domain. No direct identifiers.
- Business contacts: names, work emails, and roles of your team members who interact with us.
- Public authorship records: names and bylines of subject-matter experts cited in content work.
Obligations
- We process only on your documented instructions.
- We confidentiality-bind every employee and contractor.
- We apply appropriate technical and organizational measures: SSO, encryption in transit and at rest, least-privilege access, audit logs.
- We notify you without undue delay, and within 72 hours of awareness, of any personal data breach.
- We support you on data subject requests, DPIAs, and regulator enquiries.
Sub-processors
We engage a short list of sub-processors: payment providers, authentication, hosting, analytics, and AI-engine citation tracking. The current list is available to clients on request. We notify you before changing it, and you may object in writing.
International transfers
Where processing involves transfers outside the EEA, we rely on the European Commission's standard contractual clauses and conduct a transfer impact assessment where required.
Audits
Once per year, or after a material incident, you may audit our compliance with this DPA. We accept written questionnaires, SOC 2 reports from sub-processors, or, on reasonable notice, an on-site visit.
End of processing
On termination, we return or delete all personal data within 30 days, unless law requires retention.
Signing
Clients on paid engagements counter-sign this DPA as part of the statement of work. A standalone signed copy is available on request: legal@citesurge.com.