Processing appendix

Company

Peejee.tv VOF, trading as Gradetonic

Address

Nieuwpoortkade 2A, 1055 RX Amsterdam, The Netherlands

Chamber of Commerce

96879629

VAT

NL867812345B01

Contact

[email protected] · +31 20 369 4294

This appendix applies when you, our customer, use Gradetonic and we process personal data of your viewers on your behalf. You are the controller; Gradetonic is the processor. It sets out the practical arrangements referred to in Chapter 4 of the NLdigital Terms 2025; together they form the processing agreement under Article 28(3) GDPR. It is part of our terms of service and is accepted together with them when you create an account. Where this appendix and the NLdigital Terms differ, this appendix prevails. Below, “this agreement” means this appendix together with Chapter 4.

1. What we process for you

We process your viewers’ personal data only to provide Gradetonic: letting viewers into your rooms, enforcing viewer limits and passwords, showing you who is watching and letting you remove viewers. The details are in Annex 1.

We never record, store or analyse the picture or sound you stream.

2. Your instructions

• We process the data only on your documented instructions. Using the service as offered, and the settings you choose in your account, are your instructions.
• If we believe an instruction breaks the GDPR or other data protection law, we tell you.
• If the law requires us to process data in another way, we tell you first, unless the law forbids that.

3. Confidentiality

Everyone at Gradetonic who has access to the data is bound to confidentiality. Access is limited to what is needed to run and support the service.

4. Security

We take the technical and organisational measures in Annex 2 and keep them up to date. We may change them as long as the level of protection does not go down.

5. Subprocessors

• You give us general permission to use subprocessors. The current list is in Annex 3.
• We announce a new or replacing subprocessor by email at least 30 days in advance. You can object on reasonable grounds within that period; if we can’t resolve it, you can end your subscription before the change takes effect, without further costs.
• Each subprocessor is bound by written obligations that are at least as protective as this agreement. We remain responsible for them towards you.

6. Location

We process your viewers’ data within the European Economic Area, with one exception: the streaming statistics service in Annex 3 is located in the United States. It receives viewer IP addresses and session and traffic data, which it uses only for statistics; according to the provider, IP addresses are not stored after processing. The safeguards for this transfer under Chapter V GDPR are under review. We will inform you when they are in place, and we don’t add other transfers outside the EEA without telling you first.

7. Helping you

• Viewer requests. If a viewer asks us to exercise their rights, we pass the request to you and don’t answer it ourselves. Your viewer list and the retention periods in Annex 1 help you respond; where you need more, we assist.
• Impact assessments and the authorities. We give you the information you reasonably need for a data protection impact assessment or a question from a supervisory authority.

8. Data breaches

We notify you without undue delay, and in any case within 48 hours, after we become aware of a personal data breach affecting your viewers’ data. We tell you what happened, which data and how many people are likely affected, the likely consequences and what we are doing about it, and we keep you informed as we learn more. Notifying the authority and the people affected is your decision as controller; we help where we can.

9. Audits

On request we give you the information you need to show that we meet this agreement. If that is not enough, you may have an independent auditor check our compliance once a year, with 30 days’ notice, at your own cost, under confidentiality and without access to other customers’ data.

10. End of the agreement

When your account ends, we delete your viewers’ data within 30 days, unless the law requires us to keep it. Encrypted backups expire on their own schedule, within 12 months at the latest; until then they are only used to restore the service after a failure. On request we first give you an export of your viewer list.

11. Liability

Liability under this agreement follows article 15 of the NLdigital Terms 2025.

Annex 1: Details of the processing

Annex 2: Security measures

• All connections are encrypted (HTTPS and secure WebSocket). Rooms are protected by a viewer password or a personal invitation link.
• Viewer and admin sessions use secure, host-only cookies that expire. Passwords are stored only as strong hashes; new passwords are checked against known breaches without sending them.
• Each customer’s data is strictly separated in the application, and that separation is covered by automated tests.
• Server access is limited to Gradetonic’s administrator, with key-based login; the platform’s admin area requires two-factor authentication. Important actions are written to an audit log that cannot be changed.
• Backups are encrypted and stored in a separate data center. Restoring a backup is tested automatically every week.
• We minimise data: no recordings of streams, viewer names only when you ask for them, IP addresses removed after 30 days.
• Software is kept up to date, and the platform is monitored around the clock.

Annex 3: Subprocessors

The complete list, with every subprocessor’s name, is in your account under Admin › Privacy.