Data Processing Agreement
Last updated: 28 May 2026
This Data Processing Agreement (the “DPA”) governs how
Pistio processes personal data on behalf of organisations using
Moimio. It mirrors the processor clauses agreed at checkout as part
of the Moimio Terms; the two are kept consistent. For most customers
the version agreed at checkout is sufficient. A countersigned copy is
available to organisations whose own compliance requires a separate
signed agreement.
This DPA forms part of the agreement between:
(1) The Customer — the organisation that holds
a Moimio account (“Controller”); and
(2) Pistio, a sole trader registered in the United
Kingdom, of 66 Paul Street, London EC2A 4NA
(“Processor”),
and governs the Processor’s processing of personal data on the
Controller’s behalf in connection with the Moimio service.
1. Definitions
Terms such as “personal data”, “processing”,
“controller”, “processor”, “data
subject”, and “personal data breach” have the
meanings given in the UK GDPR and EU GDPR as applicable.
“Applicable Data Protection Law” means the UK GDPR, the EU
GDPR, and any other data-protection laws applicable to the
processing.
2. Subject matter, nature, and purpose
The Processor processes personal data on the Controller’s
behalf solely to provide the Moimio service: the registration of
event participants and their assignment to rooms, groups, and teams
according to the Controller’s configuration. Processing
continues for the duration of the Controller’s Moimio account.
3. Categories of data and data subjects
See Annex 1.
4. Controller instructions
4.1 The Processor processes the personal data only on the
Controller’s documented instructions, including as set out in
this DPA, the Moimio Terms, and the Controller’s configuration
and use of the software.
4.2 The Processor informs the Controller if, in its opinion, an
instruction infringes Applicable Data Protection Law.
4.3 The Processor does not use the personal data for its own purposes.
5. Processor obligations
The Processor shall:
-
ensure that persons authorised to process the personal data are
bound by an obligation of confidentiality;
-
implement the technical and organisational security measures set
out in Annex 2;
- respect the conditions in clause 6 for engaging subprocessors;
-
taking into account the nature of the processing, assist the
Controller by appropriate measures, so far as possible, in
fulfilling the Controller’s obligation to respond to requests
by data subjects exercising their rights;
-
assist the Controller in ensuring compliance with its obligations
relating to security, breach notification, data protection impact
assessments, and prior consultation, taking into account the nature
of processing and the information available to the Processor;
-
at the Controller’s choice, delete or return the personal data
at the end of the provision of services, and delete existing copies,
as described in clause 8;
-
make available to the Controller information necessary to
demonstrate compliance with this DPA, and allow for and contribute
to audits as set out in clause 9.
6. Subprocessors
6.1 The Controller grants general authorisation to the Processor to
engage the subprocessors listed in Annex 3.
6.2 The Processor imposes data-protection obligations on each
subprocessor equivalent to those in this DPA, and remains fully liable
to the Controller for the performance of each subprocessor.
6.3 The Processor informs the Controller of any intended addition or
replacement of a subprocessor, giving the Controller a reasonable
opportunity to object.
7. Personal data breach
The Processor notifies the Controller without undue delay after
becoming aware of a personal data breach affecting the
Controller’s personal data, and provides the Controller with the
information reasonably necessary for the Controller to meet its own
breach notification obligations.
8. Deletion and return
On closure of the Controller’s account, participant personal
data is made available to the Controller for export for 30 days, then
erased in line with the Moimio retention schedule. The workspace and
its data, including routine backups, are permanently erased within 44
days of account closure, save that copies present in routine backups
age out of the backup retention schedule within a maximum of six
months for individually deleted events.
9. Audit
The Processor makes available to the Controller information necessary
to demonstrate compliance with this DPA and contributes to reasonable
audits, including inspections, conducted by the Controller or an
auditor mandated by the Controller, on reasonable notice and subject
to confidentiality.
10. International transfers
Personal data is hosted and processed within the European Union
(Germany). The Processor, Pistio, is established in the United
Kingdom and accesses the personal data from there to operate and
support the service. Personal data therefore moves between the United
Kingdom and the European Economic Area; those flows are covered by the
European Commission’s adequacy decision for the United Kingdom
and by the United Kingdom’s recognition of the EEA, so no
additional transfer safeguards are required. The Processor does not
transfer the personal data to any country outside the United Kingdom
or the EEA except under safeguards permitted by Applicable Data
Protection Law.
11. EU and UK representatives
For any data-protection matter in connection with this agreement,
including the role of an EU representative under Article 27 EU GDPR
where one is required, contact
[email protected].
12. Liability and governing law
12.1 Each party’s liability under this DPA is subject to the
limitations and exclusions of liability set out in the Moimio Terms.
12.2 This DPA is governed by the laws of England and Wales.
Annex 1 — Categories of data and data subjects
Data subjects: participants in events organised by
the Controller (for example, attendees of retreats, conferences, or
camps).
Categories of personal data: names; contact details
(such as email address); dietary, allergy, or accessibility
requirements where entered by the Controller; group, room, and team
assignments; and any other information the Controller chooses to enter
about participants.
Dietary, allergy, or accessibility information may constitute
special-category (health) data. The Controller is responsible for
ensuring it has a lawful basis for entering such data.
Annex 2 — Security measures
- Hosting within the EU (Germany).
-
Per-tenant isolation: each Controller’s workspace runs in its
own isolated container with its own database.
- Access controls limiting access to authorised persons.
- Encryption of data in transit (HTTPS/TLS).
- Regular encrypted backups, with defined retention and erasure.
-
Logical separation of each Controller’s data from every other
Controller’s data.
Annex 3 — Subprocessors
| Subprocessor | Role | Location |
| Hetzner | Hosting and infrastructure | Germany (EU) |
| Paddle | Payment processing (Merchant of Record) | EU / global |
| Mailjet | Transactional email delivery | EU |
| Cloudflare | DNS, content delivery, website hosting | Global |
A countersigned PDF copy of this agreement is available to customers
on request. Write to
[email protected].