PERSONAL DATA PROCESSING AGREEMENT

of the 5-Star Planet® platform

Version: 5

Date: 27 July 2026

This Personal Data Processing Agreement is entered into between the User, acting as controller of personal data, and 5-STAR PLANET S.R.L., as processor, whose full identification details are set out in Annex I.

The Clauses below reproduce, without any modification of content, the text of the Standard Contractual Clauses set out in the Annex to Commission Implementing Decision (EU) 2021/915 of 4 June 2021 on standard contractual clauses between controllers and processors, adopted pursuant to Article 28(7) of Regulation (EU) 2016/679 (the "Clauses"), with the options chosen by the Parties as indicated in the footnotes below and with Annexes I-III completed, in accordance with Clause 2(a), which permits only the completion or updating of the information in the Annexes.

ANNEX – Standard contractual clauses

SECTION I

Clause 1 — Purpose and scope

(a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

(b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.

(d) Annexes I to III are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2 — Invariability of the Clauses

(a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3 — Interpretation

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4 — Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5 — Optional — Docking clause

(a) Any entity that is not a Party to these Clauses may, with the agreement of all the Parties, accede to these Clauses at any time as a controller or a processor by completing the Annexes and signing Annex I.

(b) Once the Annexes in (a) are completed and signed, the acceding entity shall be treated as a Party to these Clauses and have the rights and obligations of a controller or a processor, in accordance with its designation in Annex I.

(c) The acceding entity shall have no rights or obligations resulting from these Clauses from the period prior to becoming a Party.

SECTION II — OBLIGATIONS OF THE PARTIES

Clause 6 — Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7 — Obligations of the Parties

7.1. Instructions

(a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b) The processor shall immediately inform the controller if, in the processor's opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing

(a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person's sex life or sexual orientation, or data relating to criminal convictions and offences ("sensitive data"), the processor shall apply specific restrictions and/or additional safeguards.

7.6. Documentation and compliance

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller's request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7. Use of sub-processors

(a) OPTION 2: GENERAL WRITTEN AUTHORISATION: The processor has the controller's general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 5 (five) days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) At the controller's request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) The processor shall remain fully responsible to the controller for the performance of the sub-processor's obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

(e) The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8. International transfers

(a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7 for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8 — Assistance to the controller

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects' requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller's instructions.

(c) In addition to the processor's obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

1. the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a 'data protection impact assessment') where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;

2. the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;

3. the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;

4. the obligations in Article 32 of Regulation (EU) 2016/679.

(d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9 — Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679, where applicable, taking into account the nature of processing and the information available to the processor.

9.1. Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant (unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

(b) in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller's notification, and must at least include:

1. the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;

2. the likely consequences of the personal data breach;

3. the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c) in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2. Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a) a description of the nature of the breach (including, where possible, the categories of data subjects concerned, as well as the approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller's obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III — FINAL PROVISIONS

Clause 10 — Non-compliance with the Clauses and termination

(a) Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

1. the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;

2. the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;

3. the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1(b), the controller insists on compliance with the instructions.

(d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

SECTION IV — SUPPLEMENTARY PROVISIONS

The following provisions supplement the Clauses above, as permitted under Clause 2(b), and do not directly or indirectly contradict them.

11.1. This Agreement supplements the Platform's Terms and Conditions (Section 7) and the Privacy Policy. By creating a User account, in accordance with Section 3.2 of the Terms, the Controller expressly accepts this Agreement, including the Clauses set out above.

11.2. This Agreement is governed by Romanian law, and disputes shall be resolved by the competent courts, in accordance with Section 15 of the Platform's Terms.

ANNEX I — List of parties

Controller: The User identified through the account created on the 5-Star Planet® Platform (name/company name and contact details as provided upon registration).

Processor: 5-STAR PLANET S.R.L., Bucharest, Sector 5, Str. Ana Davila, No. 6D, room 1, Floor 1, Apartment 3, J2026014776009, Romanian Tax ID (CUI) 54170047, contact: echipa@groupntravel.com.

Signature and accession date: The Agreement is deemed concluded upon the creation of the User account, in accordance with the Platform's Terms, on the date the account is created.

ANNEX II — Description of the processing

Categories of data subjects whose personal data is processed: Contributors and other individuals whose data may be mentioned by the User in the description of Projects or Tasks (for example, collaborators, employees, or representatives of corporate Contributors).

Categories of personal data processed: Name, contact details (e-mail address, phone number), role or type of contribution, allocated shares, comments, and any other personal data that the User chooses to include in User-Generated Content.

Sensitive data processed (if applicable) and applied restrictions or safeguards: Not currently collected or processed by the Platform. The inclusion of such data on the Platform remains the sole responsibility of the Controller, who must ensure the necessity, lawfulness, and adequate safeguards of any such processing.

Nature of the processing: Storage, hosting, display, and technical operations necessary for the functioning of the Platform.

Purpose(s) for which the personal data is processed on behalf of the controller: Management by the User of Projects, Tasks, and the relationship with Contributors, in accordance with the Platform's Terms and Conditions.

Duration of the processing: For as long as the User-Generated Content is retained on the Platform, until deleted by the User or upon termination of the account, subject to the retention periods set out in the Privacy Policy and the technical limitations on data deletion set out in the Privacy Policy.

For processing by (sub-)processors — subject matter, nature, and duration of the processing: Technical hosting and storage of User-Generated Content, for the entire duration of the processing described above, by the sub-processors engaged in accordance with Clause 7.7 (Option 2).

International transfers

To the extent that the processing involves the transfer of personal data to sub-processors established in third countries (including the cloud infrastructure providers Google and Linode), such transfers are carried out in accordance with Chapter V of Regulation (EU) 2016/679. The processor ensures compliance with these provisions by relying on the Standard Contractual Clauses adopted by the European Commission or other appropriate safeguards in accordance with Article 46 of Regulation (EU) 2016/679.

ANNEX III — Technical and organisational measures

Note: the measures below describe the current situation of 5-Star Planet, which does not operate its own data centres and relies on the cloud infrastructure of its sub-processors Linode (Akamai Technologies) and Google LLC.

1. Admittance control

(Preventing unauthorised physical access to data processing systems.)

5-Star Planet does not operate its own data centres; User-Generated Content is hosted exclusively in the data centres of its sub-processors Linode (Akamai Technologies, Frankfurt, Germany) and Google LLC, which are certified (ISO 27001, SOC 1-3, and other equivalent certifications) and equipped with strict physical security measures at the perimeter and access points (monitoring, intrusion detection, two-factor authentication).

2. Access control

(Preventing unauthorised access to data processing systems.)

5-Star Planet staff use two-factor authentication to access the administration consoles for the production infrastructure, and configuration changes are logged.
A strong password policy applies to administrative accounts, which are kept in a password manager with an encrypted database.
Staff workstations lock automatically after a short period of inactivity, and staff keep credentials strictly confidential.

3. Data access control

(Preventing unauthorised activities in processing systems beyond the authorisations granted.)

Servers that process or store User-Generated Content are not directly accessible from the public internet; access is only possible through administrative or load-balancing components with public IP addresses.
Audit trails for changes made to the infrastructure and to Users' data by 5-Star Planet staff are automatically generated and may be reviewed periodically.

4. Input control

(Ensuring transparency and documentation of data administration and maintenance.)

Changes made to User-Generated Content are logged, including the identity of the user who made the change, to the extent permitted by the Platform's architecture.
If a Platform update requires modifying Users' data, this is documented in the release notes for the relevant version.

5. Purpose limitation / separation control

(Data collected for different purposes is processed separately.)

Users can define permissions for Contributors at the functionality level and at the group or individual user level within their organisation.
Each User's data is separated from other Users' data at the database level.
The Platform's production, testing, and development environments are distinct.

6. Sub-processing chain

(For services provided through sub-processing, ensuring compliance with the contractual obligations between the entity and the sub-processing service provider.)

For services provided through sub-processing (Linode, Google), 5-Star Planet ensures that the sub-processor fully complies with the contractual obligations assumed, as well as with the supervisory authority's right to audit.
5-Star Planet's use of sub-processors does not affect its contractual obligations, roles, and responsibilities towards the Controller.
At the Controller's request, 5-Star Planet will provide information on the roles and responsibilities of the sub-processors that have access to, or are involved in, the processing of Users' data.
5-Star Planet will inform the Controller, in accordance with Clause 7.7, prior to any significant change of sub-processors involved in providing the service, in a manner that allows the Controller to carry out a risk assessment before the change takes effect.

7. Data protection

(Ensuring data security, data protection, and confidentiality.)

Communication between the Platform and users takes place exclusively over encrypted connections (HTTPS/TLS).
User authentication is carried out through a third-party provider (Google), which applies its own cryptographic protection measures.
5-Star Planet relies on the data security measures implemented by its sub-processors (Linode, Google) and, to the extent permitted by its contractual relationship with them, periodically obtains assurance of their compliance with data security and protection requirements.

8. Data handling, processing, and storage

(Ensuring the availability of data stored in the cloud and its protection against unauthorised access and modification.)

Data is hosted and processed in compliance with national law and EU legal instruments, in the following regions: Germany (Frankfurt, via Linode/Akamai Technologies) and the region(s) used by Google LLC for hosting the Platform's static content.
All User data, including backups, is stored on media encrypted in line with current industry standards.
Users' data is processed and stored by 5-Star Planet and its sub-processors only to the extent and for as long as necessary to achieve the purpose of the processing, in accordance with Annex II.
5-Star Planet seeks to ensure the availability of the data hosted on the Platform, its protection against unauthorised access or modification, and the storage of backup copies.

9. Security of data in transit

(Protecting data transmissions between the entity and the cloud, between resources within the cloud, and between the cloud and other external service providers, against unauthorised access and modification.)

Data transmission between the User and the Platform, as well as between infrastructure components hosted by sub-processors, is protected by encryption (HTTPS/TLS) against unauthorised access or modification.

10. Protection of resources

(Processing resources and allocated storage capacities are protected against unauthorised physical or logical access, damage, and theft.)

The Platform is hosted in a cloud environment that is logically separated from other potential customers of the sub-processors, with logical access controls, secure configurations in line with manufacturers' recommendations, and technical separation of resources belonging to different customers, managed by the sub-processors (Linode, Google).
5-Star Planet implements technical measures and procedures, even if informal, to restore the availability of User-Generated Content and of the Platform's services following a disruptive incident.

11. Security management

At this stage, 5-Star Planet S.R.L. does not itself hold an ISO/IEC 27001 or SOC certification; these certifications belong exclusively to its sub-processors (Linode/Akamai Technologies, Google), in whose data centres Users' data is hosted.
5-Star Planet applies risk-proportionate measures for configuration management, system updates, and staff training on data protection.

12. Operations security

5-Star Planet applies operating procedures covering at least: the definition of operational responsibilities, backup and restore procedures, monitoring of operations and log management, change and version management for the Platform, and incident management.

13. Security of development

Development of the Platform follows documented secure development practices; changes are subject to review before release, and the development/testing environment is separate from the production environment.

14. User and access rights management

5-Star Planet maintains a procedure, even if informal at this stage, for managing access rights for its own staff who administer the Platform, including the request, approval, and periodic review of access.
Multi-factor authentication is used at least for users with privileged rights, and their activity is logged and reviewed periodically.

Specific technical and organisational measures by which the processor provides assistance to the controller (Clause 8(d) and Clause 9.2 in fine): notification without undue delay to the Controller of data subject requests and of any data security breaches, through the contact address indicated in Annex I.

📢 Feature your startup here!

GROUPnTRAVEL is a marketplace matching nonprofits with hotels or holiday rentals.

Start building a 5-star community around your hotel.

Visit GROUPnTRAVEL