Data Processing Agreement

DPA for GDPR Compliance

Introduction

This Data Processing Agreement ("DPA") forms part of the Terms of Service between Panaroma Video, a company registered in the Netherlands, operating as Clickbarrier ("Processor", "we") and the customer ("Controller", "you", "Client") who uses our click fraud protection services.

Panaroma Video
Vorstenburg 5, 1506RE, Zaandam, Netherlands
KVK: 92841449 | BTW-id: NL004981079B76

This DPA reflects the parties' agreement regarding the processing of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR) and other applicable data protection laws.

1. Scope and Purpose of Processing

1.1 Subject Matter

The Processor will process personal data on behalf of the Controller for the following purposes:

Collecting and analyzing visitor data from Controller's websites
Detecting fraudulent clicks and suspicious activity
Blocking malicious IP addresses
Managing Google Ads IP exclusion lists

1.2 Categories of Data Subjects

Visitors to Controller's websites
Users who click on Controller's advertisements

1.3 Types of Personal Data

Data	Description
IP Address	Visitor IP address (IPv4/IPv6)
User Agent	Browser and device information
Client Hints	Platform, model, architecture info
Referrer	Traffic source
Timestamp	Visit date and time

2. Processor Obligations

2.1 Instructions

We will process personal data only on documented instructions from the Controller.

2.2 Confidentiality

We will ensure persons authorized to process personal data are under confidentiality obligations.

2.3 Security

We will implement appropriate technical and organizational security measures as required by GDPR Article 32.

2.4 Data Breach Notification

We will notify the Controller within 48 hours of becoming aware of a personal data breach.

2.5 Deletion

At the end of services, we will delete or return all personal data at the Controller's choice.

3. Sub-processors

The following sub-processors are authorized:

Name	Purpose	Location
Google Ads	IP Blocking API	US
Telegram	Notification Service	Various

We will notify you at least 30 days in advance of any changes to sub-processors.

4. Data Retention

Data Type	Retention Period
Visitor logs	90 days
Blocked IP records	Until block is removed

5. International Data Transfers

When personal data is transferred outside the EEA, we ensure appropriate safeguards are in place:

Standard Contractual Clauses: EU Commission-approved SCCs apply
Google: Uses GDPR-compliant SCCs for Google Ads API

6. Contact Information

Panaroma Video

Operating as Clickbarrier

Vorstenburg 5, 1506RE, Zaandam, Netherlands

KVK: 92841449

BTW-id: NL004981079B76

Data Protection Officer

Email: [email protected]