Data Processing Agreement

Last updated: 12 September 2026 · Between UNIVERSAL GLOBAL SERVICES LTD (UGS) and the customer · Contact: [email protected]

This Data Processing Agreement (DPA) forms part of the Terms of Service and applies where UGS processes personal data on behalf of a customer in connection with LaunchLens. It is entered into automatically when you use the service and can be requested as a signed copy at [email protected].

1. Roles and scope

• The customer is the controller of the data relating to its website and users.
• UGS acts as processor providing the LaunchLens analytics service.
• Subject matter: provision of cookieless analytics, dashboards, and reports.
• Duration: while the customer account is active, plus the retention period described in the Privacy Policy.

2. Nature, purpose and data categories

• Processing operations: collection of aggregated analytics events through the snippet, storage of aggregates, and display in the dashboard.
• Categories of personal data: aggregated event data, page paths, referrers, and UTM parameters. No cookies, no fingerprinting, and no names or emails of website visitors are collected by the snippet.
• Categories of data subjects: visitors to the customer website.
• Account data (customer email) is processed as described in the Privacy Policy.

3. Processor obligations

• Process personal data only on documented instructions from the controller, including these Terms and the product settings.
• Ensure that persons authorised to process the data are bound by confidentiality.
• Apply appropriate technical and organisational security measures, including encryption in transit, hashed API secrets, and least-privilege access.
• Assist the controller with data subject requests; the product provides export and deletion in Settings.
• Notify the controller without undue delay after becoming aware of a personal data breach.

4. Sub-processors

UGS uses the following categories of sub-processors: cloud infrastructure hosting, payment processing (Stripe), and transactional email delivery. Sub-processors are bound by data processing agreements. A current list is available on request from [email protected]. The controller is notified of changes with the opportunity to object.

5. International transfers

Where personal data is transferred outside the EEA, UGS relies on appropriate safeguards such as the European Commission Standard Contractual Clauses.

6. Deletion and return

On termination, personal data is deleted according to the retention settings and the Privacy Policy, unless retention is required by law. Aggregated, non-identifying statistics may be retained.

7. Audits

UGS provides the information reasonably necessary to show compliance, including the security and processing information published in these pages.

8. Contact

Data protection enquiries: [email protected]