Effective date: [TO BE SET AT PUBLICATION] Version: 0.1.0
This Data Processing Addendum (“DPA”) forms part of the TicketQuill Terms of Service between the customer identified in the applicable TicketQuill account or Discord installation (“Customer”) and Black Tide Studio (“TicketQuill”).
This DPA applies only to personal information that TicketQuill processes on Customer’s behalf as a processor, service provider, or equivalent role under applicable data-protection law (“Customer Data”). It does not govern information TicketQuill processes for its own independent purposes, such as its own security, billing, legal, support, or account-administration records.
1. Roles
For Customer Data, Customer is the controller/business or equivalent party and TicketQuill is the processor/service provider to the extent required by applicable law.
Customer determines the purposes and means of processing Customer Data and gives TicketQuill documented instructions through the Service configuration, these Terms, this DPA, and reasonable support requests consistent with the Service.
2. Subject matter and duration
TicketQuill processes Customer Data to provide, maintain, secure, troubleshoot, and support the TicketQuill Service for the duration of Customer’s use of the Service and for limited post-termination periods necessary for deletion, backup expiry, legal compliance, or security.
3. Nature and purpose of processing
Processing may include collection, organization, storage, retrieval, transmission, display, configuration, support, security monitoring, deletion, and other processing reasonably necessary to operate the Service.
4. Categories of data and data subjects
Customer may instruct TicketQuill to process identifiers, Discord identifiers, ticket operational metadata, form responses, configuration information, and other information submitted through the Service.
Data subjects may include Discord server members, customers, staff, moderators, administrators, and other individuals whose information Customer places into the Service.
Customer must not intentionally instruct TicketQuill to process highly sensitive information prohibited by the Terms unless TicketQuill has expressly agreed in writing after appropriate legal and technical review.
5. Customer responsibilities
Customer will:
- ensure that processing instructions are lawful;
- provide required privacy notices to data subjects;
- establish an appropriate legal basis for processing;
- configure TicketQuill to collect only information reasonably necessary for the intended purpose;
- manage Discord permissions, roles, staff access, and administrator accounts;
- respond to data-subject requests where Customer is the controller/business;
- comply with applicable data-protection, consumer-protection, and children's-privacy requirements; and
- notify TicketQuill if an instruction would require processing that TicketQuill cannot lawfully or technically perform.
6. TicketQuill obligations
TicketQuill will:
- process Customer Data only on documented instructions, unless processing is required by applicable law;
- ensure persons authorized to process Customer Data are subject to confidentiality obligations;
- implement reasonable technical and organizational security measures appropriate to the processing;
- assist Customer, where reasonably practicable and required by applicable law, with data-subject requests, security obligations, and regulatory inquiries;
- notify Customer without undue delay after confirming a security incident involving Customer Data where notification is required by law or this DPA;
- delete or return Customer Data at the end of the Service relationship as required by the Terms, this DPA, and applicable law; and
- make available information reasonably necessary to demonstrate compliance with applicable processor obligations.
7. Subprocessors
Customer gives general authorization for TicketQuill to use subprocessors reasonably necessary to provide the Service.
Current subprocessors that process Customer Data are listed in the TicketQuill Privacy Policy. TicketQuill will provide notice of intended additions or replacements where required by applicable law. Customer may object on reasonable data-protection grounds within the period required by applicable law.
If an objection cannot reasonably be resolved, TicketQuill may offer a commercially reasonable alternative where available or allow Customer to stop using the affected processing feature.
8. Security measures
TicketQuill maintains safeguards appropriate to its size, architecture, and risk profile. Current measures include:
- Database-enforced tenant isolation. Row-level security is forced on every tenant table, and the application connects using a runtime role that cannot bypass it. Isolation is enforced by the database itself, not only by application logic.
- Separated database roles. The schema-owning role and the runtime role are distinct, and the runtime role holds only the privileges the Service needs.
- Credential separation between processes. The dashboard process does not receive the Discord bot token. Requested Discord changes travel through a durable, revalidated outbox rather than direct browser-driven calls.
- Encryption in transit for the dashboard and for connections to Discord.
- Session protection. Sessions are hashed opaque identifiers; raw IP addresses are not retained for behavioural analytics.
- No payment credentials. Payment-card numbers, security codes, and raw payment-method data are never received or stored by TicketQuill.
- Backup and recovery controls, including automated verification that each backup is readable, and access-restricted backup storage.
- Security and access logging; vulnerability and dependency management; incident detection and response procedures; and confidentiality obligations for anyone with access to Customer Data.
Backup files are currently access-restricted rather than encrypted at rest. TicketQuill does not represent that data is encrypted at rest.
TicketQuill may update these measures as its architecture changes, provided the overall security of processing is not materially reduced.
9. Security incidents
If TicketQuill confirms a security incident involving Customer Data, TicketQuill will notify Customer without undue delay where notification is required by applicable law or reasonably necessary for Customer to meet its own obligations.
To the extent reasonably available, the notice will describe the nature of the incident, categories of information affected, known or suspected impact, and mitigation measures. TicketQuill will provide reasonable updates as material information becomes available.
Customer remains responsible for notifying affected individuals or regulators where Customer is legally required to do so, except to the extent TicketQuill has an independent legal obligation.
10. Data-subject requests
If TicketQuill receives a request from an individual concerning Customer Data for which Customer is controller, TicketQuill may direct the individual to Customer and will reasonably assist Customer where required by applicable law.
TicketQuill will not independently respond to or disclose Customer Data except as instructed by Customer, required by law, or necessary to protect rights, security, or the Service.
11. Government requests
If TicketQuill receives a legally binding request from a governmental authority for Customer Data, TicketQuill will, where legally permitted, notify Customer before disclosure and provide reasonable assistance to challenge or narrow the request. TicketQuill will disclose only the information legally required.
12. International transfers
Where Customer Data is subject to EU/EEA transfer restrictions, the parties will use an applicable lawful transfer mechanism.
Where required for a transfer to a non-EEA country, the parties may rely on the European Commission’s Standard Contractual Clauses or another valid transfer mechanism, together with any supplementary measures required by applicable law.
For UK restricted transfers, the parties will use the applicable UK transfer mechanism, including the UK International Data Transfer Agreement, UK Addendum, adequacy regulations, or another lawful mechanism as applicable.
13. Deletion and return
At Customer’s request following termination, TicketQuill will delete Customer Data within the periods described in the Privacy Policy, subject to legal retention requirements and the normal expiration of backups on their rolling schedule.
Where the Service architecture does not provide a practical export mechanism, TicketQuill is not required to create a custom export at no charge, but will provide reasonable assistance available through normal Service functionality.
14. Audits and compliance information
Customer may request information reasonably necessary to demonstrate TicketQuill’s compliance with applicable processor obligations. Where legally required and where a reasonable documentary review is insufficient, Customer may request a remote audit or other proportionate assessment, subject to reasonable notice, confidentiality, security restrictions, and protection of other customers’ information.
Audits must not unreasonably interfere with TicketQuill operations or expose security-sensitive information, trade secrets, or information belonging to other customers.
15. Conflict and precedence
If this DPA conflicts with the TicketQuill Terms of Service concerning the processing of Customer Data, this DPA controls for that specific processing matter.
If applicable law imposes a mandatory requirement that cannot be contractually changed, that requirement controls.
16. Liability
The liability provisions of the TicketQuill Terms apply to this DPA unless applicable law requires otherwise.
Nothing in this DPA is intended to limit a party’s liability to the extent such limitation is prohibited by applicable law.
17. Contact
Privacy and DPA requests: privacy@ticketquill.com Security incidents: security@ticketquill.com