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Data Processing Agreement

Last updated: June 12, 2026

1. Parties, Roles, and Scope

This Data Processing Agreement ("DPA") forms part of the Terms of Service between DotEnv Inc. ("DotEnv", the "Processor") and the customer organization ("Customer", the "Controller") and applies to the extent DotEnv processes personal data contained in Customer Data on Customer's behalf. For the personal data of registered users that DotEnv processes for its own purposes (account, billing, security), DotEnv acts as an independent controller as described in the Privacy Policy.

"Data Protection Laws" means all laws applicable to the processing of personal data under this DPA, including PIPEDA, Quebec Law 25, the EU and UK GDPR, and the CCPA/CPRA. Terms such as "personal data", "processing", "controller", and "processor" have the meanings given in those laws.

2. Details of Processing

  • Subject matter: provision of the DotEnv secrets and environment variable management service.
  • Duration: the term of the Terms of Service, plus the post-termination export and deletion period.
  • Nature and purpose: encrypted storage, transmission, organization, versioning, audit logging, and retrieval of Customer Data as instructed through the Service.
  • Categories of data subjects: Customer's employees, contractors, and other authorized users; individuals whose data appears in Customer Data.
  • Categories of personal data: account identifiers of Customer's users (name, email, role); any personal data Customer chooses to include in stored secrets or configuration values. Customer should not store special categories of personal data in the Service.

3. Processor Obligations

DotEnv will:

  • Process Customer Data only on Customer's documented instructions (the Terms, this DPA, and use of the Service's controls constitute such instructions), unless required by law, in which case DotEnv will inform Customer unless legally prohibited;
  • Ensure persons authorized to process Customer Data are bound by confidentiality obligations;
  • Implement and maintain the technical and organizational measures described in Annex B (consistent with GDPR Article 32);
  • Assist Customer, taking into account the nature of processing, with data subject requests and with Customer's obligations regarding security, breach notification, and data protection impact assessments;
  • Make available information reasonably necessary to demonstrate compliance with this DPA;
  • Notify Customer without undue delay if it considers an instruction infringes Data Protection Laws.

4. Subprocessors

Customer provides general authorization for DotEnv to engage the subprocessors listed on the Subprocessors page. DotEnv will: (a) impose data protection obligations on subprocessors no less protective than this DPA; (b) remain liable for its subprocessors' performance; and (c) provide at least 30 days' advance notice of new subprocessors (via the Subprocessors page and/or email). Customer may object on reasonable data protection grounds within that period; if the parties cannot resolve the objection, Customer may terminate the affected services and receive a pro-rata refund of prepaid fees.

5. International Transfers

Customer Data is processed in Canada and the United States (and other locations listed on the Subprocessors page). Where transfers of EEA/UK personal data to third countries occur, the parties incorporate by reference the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914), Module Two (controller-to-processor), with Customer as data exporter and DotEnv as data importer, and the UK International Data Transfer Addendum where UK GDPR applies. Annexes A and B of this DPA serve as the corresponding SCC annexes.

6. Personal Data Breach

DotEnv will notify Customer without undue delay, and in any event within 72 hours, after becoming aware of a personal data breach affecting Customer Data. The notification will describe, to the extent known, the nature of the breach, the categories and approximate volume of data and data subjects affected, likely consequences, and measures taken or proposed. DotEnv will cooperate with Customer's reasonable investigation and remediation efforts. Notification is not an admission of fault.

7. Audits

DotEnv will satisfy audit requests first through documentation, security descriptions, and available third-party reports. Where Data Protection Laws grant Customer a mandatory audit right that cannot be satisfied this way, Customer may conduct (directly or via an independent auditor bound by confidentiality) an audit of DotEnv's relevant processing facilities: maximum once per 12-month period, on at least 30 days' written notice, during business hours, without disrupting operations, and at Customer's expense.

8. Return and Deletion

During the term, Customer can export Customer Data using the Service's export features. Following termination, Customer has 30 days to export Customer Data, after which DotEnv will delete Customer Data within 60 days, except where retention is required by law. Where Customer uses client-managed encryption keys, DotEnv holds only ciphertext, and deletion of ciphertext (or Customer's destruction of its keys) renders the data permanently unreadable.

9. CCPA/CPRA Service Provider Terms

To the extent the CCPA/CPRA applies, DotEnv acts as a "service provider": it will not sell or share Customer personal information, will not retain, use, or disclose it for any purpose other than providing the Service (or as otherwise permitted by the CCPA/CPRA), and certifies that it understands these restrictions.

10. Liability and Order of Precedence

Each party's liability under this DPA is subject to the limitations of liability in the Terms of Service, except where Data Protection Laws prohibit such limitation. In case of conflict, this DPA prevails over the Terms with respect to processing of personal data; the SCCs prevail over this DPA where they apply.

Annex A: Description of Processing

As set out in Section 2. Frequency: continuous, as initiated by Customer through the web application, API, CLI, and SDKs. Retention: per Section 8 and the plan's configured version-history and audit-log retention.

Annex B: Technical and Organizational Measures

  • Encryption: Customer Data encrypted at rest with AES-256-GCM; TLS for data in transit; PBKDF2-based key derivation; optional client-managed (zero-knowledge) and hybrid key custody modes;
  • Access control: organization-level isolation, role-based access control with custom roles, scoped API tokens with expiry, least-privilege internal access;
  • Authentication: verified email accounts, hashed passwords, two-factor authentication (TOTP, email, SMS), trusted-device management;
  • Auditability: audit logging of data-affecting actions, secret version history, API access metrics;
  • Operations: hosted on established cloud infrastructure (AWS) behind Cloudflare; error monitoring; environment segregation; no payment card data stored by DotEnv;
  • Resilience and lifecycle: managed backups by infrastructure providers, cascading deletion on account/organization removal, documented breach response per Section 6.

Enterprise customers requiring a countersigned DPA or negotiated terms: contact [email protected].