Variant Work

Data Processing Agreement

Last updated 12 October 2026

The short version
  • Your app’s users’ data stays yours. We process it only to deliver the job you paid for.
  • Work happens in the EU, in disposable environments, with a backup taken first.
  • AI models see code, schema and synthetic samples, never real records from your database.
  • When the job closes we delete the working copies and revoke our access.
  • We tell you without undue delay if a breach affects your data.

1. Parties and scope

This agreement is between you, the customer, as controller, and Variant Work Consulting Agency S.L., Via Laietana, 39, Planta 2, 08003 Barcelona, Spain (“we”), as processor. It forms part of our Terms of Service and applies to every paid job (App Rescue, App Independence, Production Ready and paid assessments) in which we handle personal data contained in your app, its code or its database. It meets the requirements of Article 28 of the General Data Protection Regulation (GDPR).

The personal data you give us about yourself as a customer (your account, billing and contact details) is not covered here: we are its controller, as described in our Privacy Policy.

2. Details of the processing

3. Your instructions

We process personal data only on your documented instructions, which are the accepted scope, these terms and anything you confirm in writing in the portal. If we think an instruction breaks data protection law, we tell you and pause that part of the work. If the law requires us to process data in another way, we tell you first unless the law forbids it.

4. Confidentiality

Everyone who can access your data for us, including the engineers who review your job, is bound by a written confidentiality obligation and sees only what the job needs.

5. Security

We protect your data as Article 32 GDPR requires. In particular:

6. Sub-processors

You give us general authorisation to use the sub-processors below. Each is bound by data protection terms at least as protective as this agreement, and we remain responsible for them.

We will tell you at least 14 days before adding or replacing a sub-processor that handles data from your app. You may object on reasonable data protection grounds; if we can’t resolve it, you may cancel the affected job and we refund the undelivered part.

7. Transfers outside the EEA

Your app’s data is processed in the EU. Where a sub-processor processes it outside the European Economic Area, we rely on the EU–US Data Privacy Framework where the provider is certified, or on the European Commission’s Standard Contractual Clauses.

8. Helping you

9. When the job ends

When a job closes we destroy sandboxes, repository clones and job credentials, and revoke our access. Backups taken for the job are deleted once the rollback period in the scope has passed, and at the latest 30 days after close, unless you ask us to return them first or the law requires us to keep them.

10. Audits

We make available the information needed to show we comply with this agreement. You may audit us, or have an independent auditor bound by confidentiality do so, once a year on 30 days’ notice, at your cost, without access to other customers’ data.

11. Liability and precedence

Liability under this agreement follows the limits in our Terms of Service, except where the law does not allow them. If this agreement and the Terms conflict on personal data, this agreement wins. Spanish law applies, as in the Terms.

12. Contact

Questions about this agreement: admin@variantwork.com.