# Conditional data processing appendix Draft templates only. Professional legal review under applicable Israeli law is required before binding use. These documents are not legally approved. Draft version: 2026-11-10 / draft-4 Applies only when expressly adopted for a project in which BTNXIO processes personal information on the customer’s behalf. It is not automatically part of every website build. ## 1. Conditional application and roles Before access begins, the parties identify the actual processing and decide whether this appendix applies. For processing performed solely on documented customer instructions, the customer determines the purposes and authorized uses and the provider performs only the agreed operations. Each party remains separately responsible for processing it determines for its own lawful purposes, such as its own business correspondence. Legal roles depend on actual facts; this draft does not assume GDPR applicability, a statutory role or an exemption for every arrangement. ## 2. Instructions, scope and minimization The processing schedule identifies data subjects, data categories and sensitivity, systems, permitted operations, duration and locations. Access is limited to the least information and permissions reasonably needed. Production information is not copied into public previews or test systems without a lawful, expressly agreed basis and safeguards. The provider does not sell data, use it for unrelated marketing or train unrelated AI systems on it. An instruction that appears unlawful is raised with the customer and the affected processing is not continued blindly. ## 3. Confidentiality and access authorization Persons with access are authorized for their role, informed of confidentiality/security duties and restricted to the permitted work. Authentication, credential handling, account separation and access revocation follow the approved schedule and applicable duties. Shared root credentials are avoided where feasible; secrets are not placed in source control, public tickets or contact forms. Access that is no longer required is removed and documented. ## 4. Security measures and oversight The parties document safeguards appropriate to the data and risks, including permissions, secure communications, system updates, logging boundaries, backups where agreed and incident handling. Where applicable, their arrangement addresses the Israeli Privacy Protection (Data Security) Regulations, including relevant outsourcing requirements, rather than relying on this appendix’s title as proof of compliance. Evidence and proportionate reviews are coordinated to permit oversight while protecting other customers, security details and lawful confidentiality. ## 5. Subprocessors and international access The approved schedule names the actual hosting, email, database, verification or other suppliers with access to project data, their roles and relevant locations or transfer arrangements. New or changed processing suppliers follow the agreed notification/approval procedure and applicable law before access; the provider imposes suitable confidentiality and security duties. The providers used by BTNXIO’s own inquiry form are not automatically approved for every client project. No particular country, certification or transfer safeguard is asserted without evidence. ## 6. Incidents and cooperation The provider informs the customer of an incident affecting entrusted information without undue delay after becoming aware, supplies available relevant facts and updates, and cooperates in containment, evidence preservation and remediation. The schedule allocates responsibility for legally required notices to authorities and affected people; it does not postpone a mandatory duty. No unapproved fixed number of hours, absolute detection promise or transfer of all legal responsibility to the customer is imposed. ## 7. Rights requests and legal disclosures The provider forwards requests relating to customer-controlled information through the agreed contact and assists within the lawful instructions and actual technical capability. It does not independently decide the customer’s purposes or make an unauthorized disclosure to a requester. Identity verification, response responsibility and any costs for separately scoped assistance are agreed without limiting mandatory rights. Legally compelled disclosures are limited and notified to the customer where permitted. ## 8. End of processing, return and deletion At the agreed end, the parties arrange export/return or deletion of the entrusted information and revocation of access, subject to applicable retention duties. The plan identifies copies, backups, supplier limitations, completion evidence and any data lawfully retained with restricted further use. No automatic erasure, immediate deletion from every backup or unlimited retention is presumed. The provider documents the performed return/deletion and any lawful exception rather than declaring completion without verification. ## 9. Activation and precedence This appendix becomes part of the individual agreement only through explicit adoption of its processing schedule by authorized parties before the relevant access. It supplements, rather than replaces, applicable privacy/security duties. If an instruction or general service clause conflicts with mandatory law, the law prevails and the parties document a lawful adjustment. The customer’s own notice to data subjects remains a separate responsibility according to the actual roles. ## Individual project schedule These particulars form part of the individual approved documents. An empty schedule is not an order, signature or acceptance. No information is submitted or saved through this template. - Parties, roles, project and processing duration: ________________ - Data subjects, data categories, sensitivity and permitted operations: ________________ - Systems, access roles, locations and approved subprocessors: ________________ - Security measures, reporting arrangements and review evidence: ________________ - Return/deletion, legal retention and backup treatment: ________________ ## Related drafts - [Service terms and development agreement](en-service-agreement.md) - [Privacy policy](en-privacy-policy.md) - [Hosting, maintenance and renewal policy](en-hosting-maintenance.md)