anyIP.io Data Processing Agreement

(1) Natural or legal person concluding this data processing agreement (the “Data Controller”), and(2) Elegant Networks Pte. Ltd., trading as anyIP.io (the “Data Processor”).

Data Controller and Data Processor are hereinafter collectively referred to as the “Parties” and individually as a “Party.”Taking into account that:
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(A) The Parties have entered into an agreement under which the Data Processor has agreed to provide services (as described at https://anyip.io/legal/general-conditions) and related technical support to the Data Controller (the “Agreement”);
(B) In the course of providing services to the Data Controller, the Data Processor will process Personal Data on behalf of and for the benefit of the Data Controller;
(C) Article 28(3) of Regulation (EU) 2016/679 (GDPR) requires that processing by a processor be governed by a contract binding the processor to the controller and setting out the subject‑matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects, and the obligations and rights of the controller;The Parties have concluded this data processing agreement (the “Data Processing Agreement”) and agree as follows:

1.1 Unless the context requires otherwise, the capitalised terms used in this Data Processing Agreement, including its Preamble and annexes, shall have the meanings indicated below:

‍Applicable Data Protection Laws means any national or internationally binding data protection laws or regulations applicable at any time during the term of this Data Processing Agreement to, as the case may be, the Data Controller or the Data Processor, including GDPR;
‍Data Controller means an entity or a person that has accepted the General Conditions and that determines the purposes and means of the processing of Personal Data;
‍Data Processor means Elegant Networks Pte. Ltd. (anyIP.io), which processes Personal Data on behalf of the Data Controller under this Data Processing Agreement;
‍Personal Data means any information relating to an identified or identifiable natural person;
‍Services means one or more automatic data gathering tools and proxy networking services (as described in the General Conditions) provided by anyIP.io under the Agreement;
‍Sub‑processor means a third‑party subcontractor engaged by the Data Processor which, as part of the subcontractor’s role in delivering the Services, will process Personal Data on behalf of the Data Controller.

2.1 The Data Controller shall comply with its obligations as a data controller under the Applicable Data Protection Laws in respect of its processing of Personal Data and any processing instructions it issues to the Data Processor.
2.2 The Data Controller has provided all necessary privacy notices and/or obtained all consents and rights required under the Applicable Data Protection Laws for the Data Processor to process Personal Data and provide the Services pursuant to the Agreement and this Data Processing Agreement.

3.1 The Data Processor undertakes to process Personal Data only on the documented instructions of the Data Controller, including with regard to transfers of Personal Data to a third country or an international organisation, unless required to do so by EU or EU Member State law to which the Data Processor is subject.

3.2 The Data Controller’s instructions to the Data Processor regarding the subject‑matter and duration of the processing, the nature and purpose of the processing, the type of Personal Data and categories of data subjects are as follows:

Subject Matter: Provision of the Services to the Data Controller.
‍Nature and Purpose of the Processing: The Data Processor will process Personal Data for the purposes of providing the Services and related services (if any) in accordance with the Agreement.
‍Categories of Data Subjects: Natural persons whose Personal Data the Data Controller chooses to process while using the Services and related services (if any).
‍Types of Personal Data: Data relating to natural persons that the Data Controller chooses to process while using the Services and related services (if any).
‍Duration of Processing: For as long as the Data Controller uses the Services and related services (if any).

3.3 When processing Personal Data under this Data Processing Agreement, the Data Processor shall comply with the Applicable Data Protection Laws and applicable recommendations of competent authorities.

3.4 The Data Controller entitles the Data Processor to enter into agreements with Sub‑processors on the Data Controller’s behalf for the performance of the Data Processor’s obligations under this Data Processing Agreement. The Data Processor shall maintain a list of Sub‑processors used to fulfil its obligations under this Data Processing Agreement. The Data Controller may familiarise itself with the Sub‑processors currently engaged by the Data Processor by requesting a list of such Sub‑processors from the Data Processor in writing.

4.1 To the extent reasonable, taking into account the nature of processing, the Data Processor shall assist the Data Controller in fulfilling its legal obligations under Applicable Data Protection Laws, including but not limited to the Data Controller’s obligation to respond to requests for exercising data subjects’ rights to request information and for Personal Data to be corrected, blocked, or erased at their request.

4.2 In case of any requests made by data subjects, competent authorities, or any other third parties to the Data Processor regarding the processing of Personal Data covered by this Data Processing Agreement, the Data Processor shall refer such requests to the Data Controller.

4.3 On terms agreed between the Parties and to a reasonable extent, the Data Controller shall be entitled, in its capacity as the data controller, to take measures necessary to verify that the Data Processor is able to comply with its obligations under this Data Processing Agreement and that the Data Processor has in fact undertaken the measures to ensure such compliance.

4.4 On terms agreed between the Parties and to a reasonable extent, the Data Processor shall assist the Data Controller in data protection impact assessments, prior consultations, and other communications with data protection authorities.

5.1 The Data Processor shall protect Personal Data against destruction, modification, unlawful dissemination, or unlawful access. Personal Data shall also be protected against all other forms of unlawful processing. Having regard to the state of the art and the costs of implementation, and taking into account the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of individuals, the Data Processor shall implement adequate technical and organisational measures.

5.2 The Data Processor shall ensure that access to Personal Data is granted only to employees for whom such access is necessary to perform work functions under this Data Processing Agreement and shall ensure that such employees are bound by confidentiality obligations to the same extent as the Data Processor.

5.3 The Data Processor undertakes not to disclose or otherwise make Personal Data processed under this Data Processing Agreement available to any third party without the Data Controller’s prior written consent, except for Sub‑processors engaged in accordance with this Data Processing Agreement.

5.4 The Data Processor shall take all necessary actions to assist and shall promptly notify the Data Controller in relation to any accidental or unauthorised access to Personal Data or any other security incidents (Personal Data Breach) immediately if possible.

6.1 All definitions used in this Data Processing Agreement shall have the same meaning as prescribed in the Agreement unless expressly provided otherwise in this Data Processing Agreement.
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6.2 The provisions in this Data Processing Agreement shall apply during such time that the Data Processor processes Personal Data in respect of which the Data Controller is the data controller.
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6.3 Upon expiry of this Data Processing Agreement, the Data Processor shall, at the Data Controller’s choice as communicated to the Data Processor, delete or return all Personal Data to the Data Controller and shall ensure that any Sub‑processor does the same.
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6.4 This Data Processing Agreement is an integral part of the Agreement. Any matter not expressly governed by this Data Processing Agreement shall be governed by the Agreement.


Last updated on 29 September 2025