Legal

Data Processing Agreement

BufferDesk · Skiwo AS · Pilestredet 17, 0164 Oslo · support@bufferdesk.com · Effective 26 September 2026

This Data Processing Agreement ("DPA") is part of the agreement between the Customer ("Controller") and Skiwo AS, operating BufferDesk ("Processor"), and meets the requirements of Article 28 of the GDPR. A signed copy is available on request.

1. Subject and purpose

The Processor processes personal data only to provide BufferDesk: receiving SuperOffice requests the Controller's users send to it, reading the purchase orders in them, matching buyers and lines against the Controller's Visma.net customers and items, writing sales orders on Hold into the Controller's Visma.net, emailing the Controller's order address, and reading released orders back to measure accuracy.

2. Data subjects and data

3. Duration

For the term of the agreement. On termination, the Processor deletes or returns the personal data at the Controller's choice, unless the law requires it to be kept.

4. The Processor's obligations

5. Security measures

6. Sub-processors

The Controller authorises the following sub-processors. The Processor informs the Controller before adding or replacing one, giving it the opportunity to object, and binds each to obligations equivalent to this DPA. The Processor remains responsible for them.

Sub-processorProcessingLocation
Heroku (Salesforce, Inc.)Hosting, database and managed AI inferenceEU region
Anthropic, via Heroku managed inferenceReading purchase orders with a language modelHeroku's EU inference
Amazon Web Services (SES, S3)Email delivery; storage of purchase-order attachmentsEU (Frankfurt)

SuperOffice and Visma.net are the Controller's own systems. The Processor reads from and writes to them on the Controller's instruction; they are not sub-processors of the Processor.

7. Transfers

Personal data is stored and processed in the EU/EEA. A transfer outside it requires the Controller's prior authorisation and appropriate safeguards under GDPR Chapter V, such as the Standard Contractual Clauses.

8. Breach notification and audits

The Processor notifies the Controller without undue delay, and where feasible within 72 hours, after becoming aware of a personal data breach, with what is known of its nature, scale, likely consequences and the measures taken.

The Controller may audit compliance on at least 30 days' notice, during business hours, no more than once a year, without unreasonably disrupting the Processor's operations.

9. Liability and law

Liability follows the limitations in the main agreement, except where the law does not allow it to be limited. This DPA is governed by Norwegian law, with Oslo District Court as venue unless mandatory law provides otherwise.

10. Contact

Skiwo AS, Pilestredet 17, 0164 Oslo, Norway · support@bufferdesk.com