Data Sub Processing Agreement for Partners

This web page represents our Data Sub Processing Agreement and applies to registering and using a Manceppo PARTNER ACCOUNT regarding our website, located at and the tools we provide you (the “Website” or the “Service”). It was last posted on 27 October 2020. The terms, “we” and “our” as used in this Agreement refer to Manceppo BV.

We may amend this Agreement at any time by posting the amended terms on our Website. We may or may not post notices on the homepage of our Website when such changes occur.

By creating a Manceppo PARTNER ACCOUNT, you’re agreeing to accept the Data Sub Processing Agreement as described on this web page.


PARTNER is able to create and manage CUSTOMER ACCOUNTS and act as billing contact on behalf of its own  CUSTOMERS without there being a direct customer relationship between the CUSTOMER and Manceppo.

In this case PERSONAL DATA of the CUSTOMER of the PARTNER is processed in the CUSTOMER ACCOUNT and this PERSONAL DATA is shared via the CUSTOMER ACCOUNT with Manceppo as a DATA SUB PROCESS.

The subject of the processing in that case is the use of a CUSTOMER ACCOUNT on behalf of a CUSTOMER of the PARTNER.

The purpose of the processing is to provide marketing services.

The category of data subjects about whom the data relates is leads and customer information from PARTNER CUSTOMERS  who are not Manceppo CUSTOMERS.

The type of data shared includes:

  • First name Last Name
  • Address and place of residence
  • Telephone number
  • E-mail
  • Company Name
  • Function
  • IP address
  • MAC address
  • Browser type
  • Times of user activity
  • Downloads
  • Registrations
  • Email activity
  • Website activity

The duration of the processing starts with the creation of a Manceppo CUSTOMER ACCOUNT and ends with the cancellation of the Manceppo CUSTOMER ACCOUNT.


The terms below which are written with a capital letters have the following meaning in this agreement:

  • CUSTOMER: a buyer of a good or service;
  • CUSTOMER ACCOUNT: the Manceppo account of a CUSTOMER;
  • DATA PROCESSOR: a Data Processor from Personal Data
  • DATA CONTROLLER: the person responsible for processing personal data within the meaning of the Personal Data Processing Act.
  • DATA SUB PROCESSOR: is the person who processes (part of) the Personal Data on behalf of the Data Processor.
  • PARTNER: a company that has accepted the Manceppo Partner Account Terms of Service and created a PARTNER ACCOUNT;
  • PARTNER ACCOUNT: the Manceppo account of a PARTNER;
  • PARTNERHSHIP: the collaboration as described in this agreement;
  • PERSONAL DATA: all data relating to an identified or identifiable living natural person

1.  Agreement to Terms

1.1  This Data Sub Processing Agreement constitute a legally binding agreement made between you, whether personally or on behalf of an entity (you), and Manceppo BV, located at Laan van Kronenburg 14, Amstelveen, NH 1183 AS Netherlands (we, us), concerning your access to and use of a Manceppo PARTNER ACCOUNT.

If you do not agree with all of the terms in this agreement, then you are prohibited from creating CUSTOMER ACCOUNTS on your own behalf in the PARTNER ACCOUNT and you must discontinue use immediately. We recommend that you print a copy of these terms for future reference.

1.2  The supplemental policies set out in Section 1.5 below, as well as any supplemental terms or documents, are expressly incorporated by reference.

1.3  We may make changes to these terms at any time. The updated version of these terms will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. You are responsible for reviewing these terms to stay informed of updates. Your continued use of a PARTNER ACCOUNT represents that you have accepted such changes.

1.4  We may update or change the PARTNER ACCOUNT from time to time to reflect changes to our products, our users’ needs and/or our business priorities.

1.5  Additional policies which also apply to your use of the PARTNER ACCOUNT include:

  • Our Terms of Service for Partner Accounts (, which apply to registering and using a Manceppo PARTNER ACCOUNT
  • Our Manceppo Privacy Policy (, which sets out the terms on which we process any personal data we collect from you, or that you provide to us. By using the Site, you consent to such processing and you warrant that all data provided by you is accurate.
  • Our general Terms of Use (, for the use of any Manceppo account

Certain parts of this Site can be used only on payment of a fee.


2.1 Both Manceppo and PARTNER are aware of the General Data Protection Regulation (GDPR) and will jointly endeavor to comply with all legal requirements.

2.2 The data processing takes place exclusively in order to be able to provide the desired service.

2.3 Manceppo may not use the PERSONAL DATA as a DATA SUB PROCESSOR of PARTNER for its own purposes.

2.4 Persons employed by or working for Manceppo who come into contact with the relevant PERSONAL DATA of PARTNER have a duty of confidentiality.

2.5 Manceppo takes appropriate technical and organizational measures so that the processing meets the requirements of the GDPR and the protection of the rights of the data subjects is guaranteed.

2.6 Manceppo helps to comply with the obligations of the DATA CONTROLLER if data subjects exercise their privacy rights (such as the right to access, correction, oblivion and data portability). Manceppo does not charge more than reasonable costs for this (max. € 100 per hour for direct hours only).

2.7 Manceppo helps to comply with the obligations regarding the obligation to report data leaks. This means that Manceppo immediately reports possible data leaks to the DATA CONTROLLER and cooperates with investigation / analysis. Manceppo does not charge any costs for handling possible data leaks at Manceppo.

2.8 Manceppo helps to comply with the obligations regarding Data Protection Impact Assessment. Manceppo does not charge more than reasonable costs for this (max. € 100 per hour for direct hours only).

2.9 Manceppo cooperates in audits by the DATA CONTROLLER or a third party engaged by the DATA CONTROLLER.

2.10 After the processing services have ended, Manceppo removes or blocks the data (or returns it to DATA CONTROLLER), unless it is legally obliged to keep it. This will be done as soon as possible, but in any case within four weeks after the end of the processing services.

2.11 Manceppo may not process the data outside organizations / countries that offer at least as many guarantees as the European Union, unless otherwise agreed in writing.

3.   Exclusion

This Agreement does not apply to the CUSTOMER ACCOUNTS that PARRTNER has access to through a PARTNER ACCOUNT where the CUSTOMER has authorized PARTNER and Manceppo for such access. In this case, Manceppo and PARTNER are both DATA PROCESSORS of CUSTOMER’ PERSONAL DATA. As both the CUSTOMER of Manceppo and PARTNER give permission to Manceppo to act as a DATA PROCESSOR in accordance with the Manceppo Privacy Policy when entering into the cooperation with Manceppo.