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Legal: Data Processing Agreement Template ​

このページでわかること: Takos の customer DPA template、processing scope、 security measures、sub-processor approval flow、operator-owned execution boundary。

This document is the public template baseline for a customer Data Processing Agreement (DPA). It is not legal advice and is not a signed agreement. Customer execution requires the applicable operator order form, legal approval, and signature process.

Status ​

FieldValue
OwnerData protection owner
Last reviewed2026-05-07
ScopeTakos Web / API, Git service profile, agent runtime profile, and Takosumi/operator-managed deploy/runtime operations used by Takos spaces
Current statusPublic template baseline
Signature statusCustomer execution requires operator / legal approval and a signed order

Regulatory Baseline ​

This template is designed around:

  • GDPR Article 28 processor contract requirements: subject matter, duration, nature and purpose, personal data categories, data subject categories, controller instructions, confidentiality, security, sub-processor flowdown, assistance, return/deletion, and audit information.
  • CCPA / CPRA service-provider and contractor contract requirements: limited purpose, no selling or sharing, no processing outside the business relationship, assistance with consumer requests, and subcontractor flowdown.

Official source links are listed at the end of this page.

1. Parties and Roles ​

Customer means the Takosumi Account holder named in the signed order form or master agreement. The Takosumi Account holder is the legal counter-party for contract, billing, and DPA signature purposes, and is fixed for the life of the DPA.

Capsule owner means the operational owner of a specific Takos Capsule under that Takosumi Account (per Space). The Capsule owner acts as Customer's delegated agent for app-local configuration and data subject request handling, but is not itself the DPA signatory.

Takos means the Takos service operator identified in the signed order form or master agreement.

Legal continuity rule: Capsule export, dedicated materialization, or re-binding may move the Capsule owner role within the Customer's scope, but the DPA Customer remains the Takosumi Account holder. Transferring the DPA Customer to a different Takosumi Account (e.g., Capsule export to a separate takosumi instance owned by a different account) requires a separate contract assignment, not a Capsule lifecycle event.

For Customer Personal Data processed through Takos spaces, repositories, deployments, agent runs, support requests, and customer-managed applications:

PartyDefault role
Customer (Takosumi Account holder)Controller, or processor where Customer processes data for its own end customer
Capsule ownerCustomer's delegated agent for app-local processing decisions; does not change Customer's controller/processor role
TakosProcessor, or sub-processor where Customer is a processor

The Takos service operator or operator account-plane provider may act as an independent controller for account administration, security, billing, fraud prevention, service analytics, and legal compliance. Those controller activities belong in the Privacy Policy and Terms of Service, not this DPA template. This does not make the Takos product the OIDC issuer, billing owner, or Capsule ledger owner.

2. Customer Instructions ​

Takos processes Customer Personal Data only according to documented Customer instructions, except where applicable law requires otherwise. Documented instructions include:

  • the signed agreement and order form
  • workspace, deployment, and app configuration selected through Takos Web / API
  • support requests made by authorized Customer users
  • written instructions accepted by the Takos data protection owner

Takos must notify Customer if Takos believes an instruction violates applicable data protection law, unless legally prohibited.

3. Details of Processing ​

ItemDescription
Subject matterProviding Takos Web / API access, spaces, source and repository service profiles, Takosumi-backed deploy orchestration, agent runtime profile, operator account-plane billing usage, support, and security operations
DurationAgreement term plus the deletion / retention period required to close the account, resolve disputes, comply with law, and maintain security evidence
Nature and purposeHosting, storing, transmitting, indexing, generating, deploying, monitoring, securing, supporting, and deleting Customer-controlled content and metadata
FrequencyContinuous while Customer uses Takos
Data subjectsCustomer admins, members, collaborators, application end users, support contacts, and people whose data Customer submits to Takos

4. Personal Data Categories ​

Takos may process the following categories where Customer uses the relevant feature:

  • account identity data: name, email address, avatar, pairwise OIDC subject (per-installation, issued by Takosumi Accounts), authentication metadata
  • workspace and access data: organization, space, role, membership, invitation, API token, session, and audit metadata
  • repository and deployment data: repository metadata, commit metadata, source artifacts, deployment records, environment variable names, build logs, and runtime logs
  • agent and application data: prompts, messages, tool inputs / outputs, uploaded files, generated artifacts, and Customer application data
  • billing and usage data: plan, subscription identifiers, usage quantities, invoice status, payment status, and tax / billing contact data
  • security and operations data: IP address, user agent, request IDs, trace IDs, incident evidence, backup records, and access logs

Customer must not submit special-category or sensitive personal data unless the signed agreement, product configuration, and security review explicitly permit that use case.

5. Sub-processors ​

Customer gives Takos general written authorization to use the sub-processors listed in /legal/subprocessors.

Before authorizing a new sub-processor that will process Customer Personal Data, Takos must:

  • document the service owner, processing purpose, data categories, and official DPA / sub-processor source links
  • complete vendor security and privacy review, storing evidence privately
  • impose written data protection obligations that are materially comparable to this template
  • remain responsible to Customer for Takos obligations delegated to the sub-processor
  • update the published sub-processor list at least 30 days before production processing where Customer notice rights apply

Customer may object in writing during the notice period on reasonable data protection grounds. If the objection cannot be resolved, Customer may stop using the affected feature or terminate the affected order according to the signed agreement.

6. Security Measures ​

Takos must maintain technical and organizational measures appropriate to the risk of processing, including:

Control areaBaseline measure
Access controlNamed user access, least privilege, service-owner review, break-glass logging
AuthenticationOAuth / session controls, API token verification, internal service signatures
EncryptionTLS in transit; managed storage encryption or equivalent at rest
SecretsSecrets managed through takosumi-private operator state and operator secret stores; no secrets in OSS source paths
Change managementPR review; portable owner check; deploy through the owning repository's entrypoint with authoritative readback; independent review and isolated rehearsal for state transitions; patch-management evidence
LoggingRequest correlation, audit logs, redaction of secrets and sensitive values
BackupsBackup / restore cadence and retention documented in operations runbooks
Incident responseSEV policy, incident response runbook, customer notification process
Vulnerability managementDependency update policy, Trivy scan, severity-based remediation SLA
Data deletionAccount / space deletion workflow and retention exceptions documented by the operator

7. Data Subject Requests ​

Takos must assist Customer with access, export, correction, and deletion requests to the extent Customer Personal Data is processed by Takos.

Customer execution requires operator approval that the data subject rights handler, manual fallback, and operational owner are recorded for the applicable managed environment.

8. Personal Data Breach ​

Takos must notify Customer without undue delay after confirming a Personal Data Breach affecting Customer Personal Data. The notice should include known facts, affected data categories, mitigation actions, and Customer-facing next steps.

The target external notification deadline is within 72 hours of confirmation unless law enforcement, legal privilege, or incomplete investigation facts require a different handling path approved by the incident commander and legal owner.

9. Return, Deletion, and Retention ​

On termination or Customer instruction, Takos must return or delete Customer Personal Data unless retention is required for legal, tax, security, fraud prevention, dispute, backup, or audit reasons.

Retention exceptions must be isolated from active processing and deleted when the exception expires. Backup deletion may follow the documented backup expiration cycle.

10. International Transfers ​

Where Customer Personal Data is transferred from the EEA, UK, Switzerland, or another jurisdiction with transfer restrictions, the signed DPA must include an approved transfer mechanism such as the applicable Standard Contractual Clauses, UK Addendum, adequacy decision, Data Privacy Framework coverage, or another lawful transfer mechanism accepted by counsel.

The published sub-processor list must identify provider region behavior and official provider transfer documentation where available.

11. Audit and Evidence ​

Takos must make reasonable compliance information available to Customer, including public policies, security summaries, and relevant audit evidence. Customer audit requests must be scoped, confidential, no more than once per year unless required after a verified breach, and must not expose other customers' data or Takos trade secrets.

12. CCPA / CPRA Service Provider Terms ​

Where CCPA / CPRA applies and Takos acts as a service provider or contractor, Takos must:

  • process Customer Personal Data only for the specific business purposes in the signed agreement
  • not sell or share Customer Personal Data
  • not retain, use, or disclose Customer Personal Data outside the direct business relationship except as permitted by law
  • provide the same level of privacy protection required by applicable CCPA / CPRA service-provider terms
  • assist Customer with consumer requests
  • require subcontractors that process Customer Personal Data to meet comparable obligations
  • notify Customer if Takos determines it can no longer meet these obligations

Annex I: Processing Details ​

FieldTemplate value
Data exporterCustomer
Data importerTakos
Processing purposeProviding Takos Web / API, Takosumi-backed deploy/runtime operation, Git service profile, agent runtime profile, operator account-plane billing usage, support, and security operations
Categories of data subjectsCustomer users, Customer collaborators, Customer application users, support contacts
Categories of personal dataIdentity, access, repository, deployment, agent, application, billing, telemetry, support, and security data
Sensitive dataNot intended unless separately agreed
Transfer frequencyContinuous while Customer uses Takos
RetentionAgreement term plus documented retention exceptions

Annex II: Technical and Organizational Measures ​

The baseline measures are the controls listed in Section 6 plus the public operations documents for on-call, incident response, backup / restore, disaster recovery, capacity planning, cost monitoring, patch management, and online DB migration safety.

Annex III: Authorized Sub-processors ​

The authorized sub-processor list is published at /legal/subprocessors and is incorporated by reference into the signed DPA once legal review approves that contract structure.