LEGAL

Data processing agreement

This agreement forms part of the terms of service between 3D Attract Ltd, UIC 208368629, 24G General Ivan Kolev St., floor 6, apt. 20, Triaditsa district, 1407 Sofia, Bulgaria (“3D Attract”, the processor) and the customer using the Services (the “Customer”, the controller). It applies whenever 3D Attract processes personal data on the Customer’s behalf. Words such as “personal data”, “processing” and “personal data breach” have the meaning given in the EU General Data Protection Regulation (GDPR).

1. Details of the processing

2. Instructions

3D Attract processes the personal data only on the Customer’s documented instructions. The terms of service, this agreement and the Customer’s use and settings in the Services are those instructions. If 3D Attract is required by EU or member-state law to process data otherwise, it will tell the Customer first unless that law forbids it. 3D Attract will tell the Customer if it believes an instruction breaks data protection law.

The Customer is responsible for having a lawful basis for the processing, for giving its data subjects the information the law requires, and for the content it uploads.

If the Customer processes the personal data on behalf of its own client (for example as an agency on the Guru plan), the Customer confirms that its client has authorised it to use 3D Attract, and 3D Attract acts as the Customer’s sub-processor. The Customer remains 3D Attract’s only point of contact and passes on its client’s instructions.

3. Confidentiality

Everyone at 3D Attract who can access the personal data is bound by confidentiality and accesses it only as needed to provide the Services.

4. Security

3D Attract applies the technical and organisational measures in the annex, and may update them as long as the overall level of protection does not go down.

5. Sub-processors

The Customer gives general authorisation for 3D Attract to use sub-processors. The current list is below. 3D Attract will give at least 30 days’ notice before adding or replacing a sub-processor, by email or in the Services, and the Customer may object on reasonable data protection grounds; if no solution is found, the Customer may end the affected Services and receive a refund of prepaid fees for the remaining period. 3D Attract imposes data protection obligations on each sub-processor equivalent to this agreement and remains responsible for them.

Sold through Link, LLC (“Link”, a Stripe company) sells the Standard, Pro and Guru subscriptions as merchant of record. It is not a sub-processor: it processes subscription payment data as an independent controller (see our privacy notice).

This list was last changed on 1 November 2026, when Anthropic was added. Twenty, Crisp and Link process only 3D Attract’s own customer, support and billing data and are listed for transparency; Cloudflare Turnstile will not be used until 30 days after we notify customers. To be told about changes, email info@3dattract.com with the subject “Sub-processor updates”. We also email the owner of every workspace at least 30 days before a change.

6. International transfers

3D Attract transfers personal data outside the European Economic Area only where there is an adequacy decision or appropriate safeguards under Chapter V of the GDPR, such as the standard contractual clauses. 3D Attract transfers personal data outside the EEA only on the Customer’s documented instructions, which include using the sub-processors listed in section 5.

Customers outside the EEA, UK and Switzerland

If the Customer is established outside the EEA and receives personal data from 3D Attract, the standard contractual clauses adopted by the European Commission (Decision 2021/914), Module 4 (processor to controller), are incorporated into this agreement, with this agreement providing the details required by their annexes; the clauses’ optional clause 7 applies, clause 17 chooses Bulgarian law and clause 18 chooses the courts of Sofia. Where the UK GDPR or the Swiss Federal Act on Data Protection applies, references in this agreement to the GDPR include those laws, and references to EU or member-state law include UK or Swiss law.

US state privacy laws

Where the California Consumer Privacy Act or a similar US state law applies, 3D Attract is the Customer’s service provider or processor. 3D Attract will not sell or share the personal data, keep, use or disclose it outside the direct business relationship or for any purpose other than providing the Services, or combine it with personal data from other sources except as that law allows. 3D Attract will tell the Customer if it can no longer meet these obligations, and certifies that it understands them.

7. Assistance

3D Attract will help the Customer, taking into account the nature of the processing, to respond to data subject requests, and with security, breach notification, data protection impact assessments and consultations with authorities. If a data subject contacts 3D Attract directly about the Customer’s data, 3D Attract will pass the request to the Customer and will not answer it itself unless instructed. Help beyond what the Services already provide may be charged at reasonable rates.

8. Personal data breaches

3D Attract will notify the Customer without undue delay, and in any case within 48 hours, after becoming aware of a personal data breach affecting the Customer’s data. The notice will describe what happened, the data and people likely affected, the likely consequences and the measures taken or proposed, with further details as they become available.

9. Return and deletion

When the Services end, the Customer can export its content for 30 days. 3D Attract then deletes the personal data, and in any case within 90 days of the end of the Services, unless EU or member-state law requires it to be kept. Backup copies are overwritten within a further 30 days. On request, 3D Attract confirms the deletion in writing.

10. Information and audits

3D Attract will make available the information reasonably needed to show compliance with Article 28 GDPR, and will allow audits by the Customer or an independent auditor it appoints, on at least 30 days’ notice, during business hours, no more than once a year (unless there has been a breach or an authority requires it), and subject to confidentiality. Each party bears its own costs.

11. General

If this agreement conflicts with the terms of service, this agreement prevails on data protection matters. The liability limits in the terms of service apply, except where the GDPR does not allow them. This agreement is governed by Bulgarian law. A signed copy is available on request at info@3dattract.com.

Annex: technical and organisational measures