Data Processing Agreement (DPA)
Version 1.0 - April 2026
This Data Processing Agreement ("Agreement") supplements the Terms and Conditions of Folio and describes how Folio processes personal data on behalf of the User within the meaning of Article 28 GDPR.
1. Parties
- Data Controller ("Controller"): the User (the couple or wedding planner) who uses Folio.
- Data Processor ("Processor"): Stef Appelhof, trading as Folio, sole proprietor based in Breda, the Netherlands. KvK number: 56285876.
Clarification per scenario
Couples using Folio directly: the couple is the Controller for the data of their guests, vendors, and team members. Folio processes this data solely on the couple's instructions.
Wedding planners using Folio on behalf of couples: the wedding planner is the Controller for the data in the wedding environments they manage. The planner is responsible for informing the couple about the use of Folio and the processing of personal data. Folio processes data on the planner's instructions.
2. Subject matter and duration
Folio processes personal data on behalf of the Controller for the purpose of providing the wedding planning platform. The processing lasts for as long as the Controller uses the Service, including the retention period after deletion (30 days) as described in the Privacy Policy.
3. Nature and purpose of processing
The processing takes place for the following purposes:
- Storing and displaying guest lists, RSVP status, and dietary requirements
- Managing budget data, tasks, timeline, and vendor contacts
- Sending RSVP invitation emails on behalf of the couple
- Providing a wedding website, gift registry, and seating chart
- Enabling data export by the Controller
4. Types of personal data
| Category | Data |
|---|---|
| Guest data | Names, email addresses, dietary requirements, RSVP status, plus-one details, household grouping |
| Couple contact data | Names, email addresses |
| Vendor data | Business name, contact person, email, phone, agreements |
| Financial data | Budget amounts, expenses, installment payments |
5. Categories of data subjects
- Wedding guests (including children if entered by the couple)
- The couple themselves
- Vendors and service providers of the couple
- Team members (master of ceremonies, wedding party, family with access)
6. Obligations of the Processor
Folio commits to the following:
- Process personal data only on the basis of documented instructions from the Controller (use of the Service constitutes such instructions)
- Ensure confidentiality for all persons who have access to the data
- Implement appropriate technical and organisational measures to protect the data (see section 8)
- Not engage sub-processors without prior consent (see section 7)
- Assist the Controller in fulfilling data subject requests (access, rectification, erasure, portability)
- Notify the Controller of a data breach within 48 hours of discovery
- Delete or return all personal data upon termination of the Service, in accordance with the retention periods in the Privacy Policy
- Make available to the Controller all information necessary to demonstrate compliance, and allow for and contribute to audits, to the extent reasonable
7. Sub-processors
Folio uses the following sub-processors. The Controller consents to these by accepting this Agreement:
| Sub-processor | Purpose | Location |
|---|---|---|
| Hetzner Online GmbH | Hosting and server infrastructure | Germany (EU) |
| Brevo (Sendinblue) | Sending transactional emails (RSVP invitations, password resets) | France (EU) |
| Stripe Inc. (future) | Payment processing | EU/US under SCCs |
Folio will notify the Controller by email of any changes to the sub-processor list. The Controller has 30 days to object. In case of objection, the Controller may terminate the Service.
8. Security measures
Folio implements the following measures to protect personal data (Article 32 GDPR):
- Encryption: passwords with bcrypt, admin credentials with AES-256-GCM, HTTPS on all connections
- Isolation: each wedding environment runs in its own isolated container with its own database
- Access control: role-based access, admin panel restricted to private networks, rate limiting on all endpoints
- Backups: daily encrypted backups with off-site storage
- Monitoring: fail2ban, firewall (ufw), security headers on all responses
9. International transfers
All data is stored and processed within the EU/EEA. No personal data is transferred to countries outside the EU/EEA, with the exception of Stripe (when active), for which Standard Contractual Clauses (SCCs) apply.
10. Data breaches
In the event of a data breach affecting the Controller's personal data, Folio will inform the Controller within 48 hours of discovery, providing:
- Nature of the data breach
- Categories of data and data subjects affected
- Measures taken and proposed
- Contact details for further information
The Controller is responsible for notifying the relevant supervisory authority if required (within 72 hours).
11. Termination
Upon termination of the Service, Folio will delete all personal data in accordance with the retention periods in the Privacy Policy (30 days after confirmed deletion). The Controller may export all data via the platform's download feature prior to termination.
12. Contact
Questions about this Data Processing Agreement:
- Email: privacy@folio.wedding
- Responsible party: Stef Appelhof
- KvK: 56285876
- Location: Breda, the Netherlands