Beacon Data Processing Agreement

Beacon Terms · Beacon Privacy · Beacon Subprocessors · Beacon · German version (binding)

This Data Processing Agreement (“DPA”) is between the customer that uses Beacon (“controller”) and Wilken UG (haftungsbeschränkt), Braugasse 14C, 50859 Cologne, Germany (“processor”).

It is formed when the customer uses Beacon under the Beacon Terms or when an individual agreement refers to this DPA. A separately signed version replaces this text where it differs.

The subject matter is the processing of personal data the customer stores in Beacon, or that Beacon creates on the customer’s behalf, so the customer can run relationships, email, calling, sequences, and field sales.

Processing lasts for the Beacon contract and the following return or deletion period. The nature of processing is storing, organising, displaying, transmitting to mailboxes the customer connects and to subprocessors, creating transcripts and drafts, backing up, and deleting.

Data subjects are the customer’s contacts, prospects, and other people the customer stores, and users the customer creates in Beacon where their data sits in customer content.

Data types are identification and contact data, company and deal data, communication content including email, attachments, phone numbers, call recordings and transcripts, notes, tasks, and field notes. Special-category data under Article 9 GDPR is out of scope. The customer gives no instruction to process it unless Wilken has agreed in writing first.

Wilken processes CRM data only on the customer’s documented instructions. Instructions are the use of Beacon, these terms, and individual instructions in text form to info@wilken.solutions. Wilken will tell the customer if Wilken believes an instruction breaches data-protection law, and may pause it until the customer confirms or changes it.

Wilken keeps the global suppression list as its own controller. That list is not a customer instruction, and the customer cannot lift entries that exist for a legal reason.

Wilken binds people with access to confidentiality. Wilken applies the technical and organisational measures below. Wilken assists the customer, with reasonable effort, with data-subject rights, data-protection impact assessments, and notices to the authority, where the information is with Wilken.

Wilken notifies the customer of a personal-data breach in the processing without undue delay after Wilken has established it.

Wilken does not give legal advice. The customer remains responsible for legal bases, notices to its contacts, consent, and advertising rules.

The customer authorises the parties named in the Beacon Subprocessor List. Wilken binds them by contract to data-protection duties equivalent to this DPA. Wilken is liable to the customer for their fault as for its own fault, within the liability rules of the Beacon Terms.

Changes are published on the list. The customer may object for an important data-protection reason, as the list describes.

A transfer to a third country happens only where the list shows it and an adequacy decision, standard contractual clauses, or another Chapter V GDPR ground exists. The customer instructs Wilken to make that transfer where the feature requires it, for example Gemini, Gmail, Microsoft, Twilio, or Resend.

Access to production is limited to people who need it for operations and support, and is protected by sign-in and roles. Workspaces are separated in the database. Secrets sit in GCP Secret Manager, not in source code. Transport is encrypted (HTTPS). The database is in Frankfurt. Call recordings are deleted at the telephony provider after they are copied. Backups follow the usual operation of the production database.

The customer may ask for a current description of the measures. An on-site audit needs reasonable notice. It must not disrupt operations disproportionately and is at the customer’s cost unless a concrete breach is the reason. Wilken may offer a report or a summary of existing subprocessor assurance instead of a second audit of the same party.

After the contract ends, Wilken deletes CRM data processed on instruction within 30 days, or returns it if the customer asks in text form before that period ends and a common format is reasonable. Statutory retention and the suppression list Wilken keeps as controller are unaffected. Backup copies are overwritten on the usual cycle.

German law applies. For merchants, Cologne is the place of jurisdiction. The Beacon Terms and the Wilken Terms apply otherwise.