Vardion

Home / Data processing agreement

Data processing agreement

Last updated: 24 October 2026

This agreement applies to every customer of the hosted Vardion console and forms part of its service agreement. On a customer's own server Vardion processes no customer data and the agreement does not apply.

1. Parties and roles

The customer is the controller. Kartia IKE, Dorylaiou 10-12, 11521 Athens, ΓΕΜΗ 170727601000 ("Vardion"), is the processor under Article 28 of Regulation (EU) 2016/679 (GDPR).

2. Subject matter, duration and purpose

Vardion processes personal data only to provide the hosted console to the customer: storing its workspace's records, assessments and findings, running the passive checks the customer sets, sending the mail the console sends and giving the support the customer asks for. Processing lasts as long as the service agreement.

3. Categories of data and data subjects

DataWhat it containsData subjects
User accountsName, email address, role, workspaces, sign-in settingsThe console users the customer sets up
Security programme recordsNames and roles of owners, crisis team members with how to reach them, assigned work, comments, document sign-offsThe customer's staff and partners
Leaked-credential findingsAccount (email address), source and dateThe customer's staff
Privacy records and data subject requestsWhat the customer enters; a data subject request is recorded by a reference and not by an email addressThe customer's data subjects
Audit logWhich account made which change and whenThe console users
Evidence filesWhatever the documents the customer uploads containAs the customer determines

The console stores no password or secret that a check finds; it records only that there is a finding and where.

4. Instructions

Vardion processes the data only on the customer's documented instructions. The agreement, the settings the customer makes in the console and its support requests are those instructions. Where Vardion considers that an instruction infringes the GDPR, it informs the customer at once.

5. Confidentiality

Only the people at Vardion who run the hosted console or answer a support request have access to the data, and each is bound by a duty of confidentiality.

6. Security measures

Vardion applies the Article 32 GDPR measures the security page sets out, among them:

7. Subprocessors

The customer gives general authorisation for the subprocessors in the table. Vardion notifies the customer by email at least 30 days before it adds or replaces a subprocessor, and the customer may object on reasonable grounds. Each subprocessor is bound by a contract with the same data protection obligations.

SubprocessorPurposeLocation
OVH SAS (OVHcloud)Hosting of the hosted console and the free domain checkData centre in Germany
Google Ireland Limited (Google Workspace)Sending and receiving emailIreland
Cloudflare, Inc.Hosting and delivery of the getvardion.com website and DNS for Vardion's domainsUnited States, delivered from the nearest data centre

8. Sources queried

When the customer turns on the leaked-credential check for a domain in its scope, the console queries the sources below. They do not process data on Vardion's behalf: they receive only the domain and return what they themselves list.

SourceWhat it answersWhat it receivesWhat it returns
XposedOrNotAccounts of a domain that appear in breachesThe domainThe accounts (email addresses) of the domain it lists
Hudson RockAccounts of a domain in infostealer logsThe domainThe accounts of the domain it lists
Have I Been PwnedAs XposedOrNot, only with a key the customer setsThe domainThe accounts of the domain it lists

9. Assistance to the customer

Vardion assists the customer in answering data subject requests, in impact assessments and in consultations with the supervisory authority, as far as they concern the console's processing. Most of it the customer does itself in the console: export, correction and deletion.

10. Personal data breach

Vardion notifies the customer of a personal data breach in the hosted console without undue delay and no later than 48 hours after becoming aware of it. The notice carries whatever of the Article 33(3) GDPR information is known, and Vardion adds the rest as it becomes known.

11. End of the agreement: return and deletion

The customer can export its data from the console in open formats at any time. When the agreement ends, Vardion gives the customer, on request, a full export of its workspace and deletes the data within 30 days, unless the law requires it to be kept. It confirms the deletion in writing. Backups taken before the deletion keep the data until they are rotated out.

12. Audits

Vardion makes available to the customer the information that demonstrates compliance with Article 28 GDPR and allows audits by the customer or an auditor it appoints, on reasonable notice and at an agreed time, without exposing other customers' data.

13. Transfers

The console's data is stored in Germany. Where a subprocessor processes data outside the European Economic Area, the transfer is based on an adequacy decision of the European Commission or on the Standard Contractual Clauses.

14. Contact

For this agreement and any data protection matter: support@getvardion.com.