Data processing terms

Last updated: 3 November 2026

These terms are part of the Terms of service of Pandora Search and apply when the customer uses the service to process personal data of other people: the people it investigates. The customer accepts them by accepting the Terms of service.

They are the European Commission's standard contractual clauses between controllers and processors (Commission Implementing Decision (EU) 2021/915 of 4 June 2021, adopted under Article 28(7) GDPR), in their official text and unchanged except for the choice of their options. What is specific to Pandora Search is in their Annexes I to IV. Anyone who asks at info@pandorasearch.com receives a copy with their details in Annex I.

SECTION I

Clause 1. Purpose and scope

(a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

(b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.

(c) These Clauses apply to the processing of personal data as specified in Annex II.

(d) Annexes I to IV are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2. Invariability of the Clauses

(a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3. Interpretation

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4. Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5 (optional). Docking clause

Not used in these Clauses.

SECTION II · OBLIGATIONS OF THE PARTIES

Clause 6. Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7. Obligations of the Parties

7.1. Instructions

(a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing

(a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

7.6. Documentation and compliance

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7. Use of sub-processors

(a) The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least thirty (30) days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

(e) The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8. International transfers

(a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8. Assistance to the controller

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions

(c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

(1) the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;
(2) the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;
(3) the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;
(4) the obligations in Article 32 of Regulation (EU) 2016/679.

(d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9. Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

(b) in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller’s notification, and must at least include:

(1) the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
(2) the likely consequences of the personal data breach;
(3) the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c) in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III · FINAL PROVISIONS

Clause 10. Non-compliance with the Clauses and termination

(a) Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

(1) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;
(2) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;
(3) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

(d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

ANNEX I · List of parties

Controller: the Pandora Search customer who accepts the Terms of service.

Name: the customer's name or company name, as it appears in their account or on their invoice.
Address: the one on their invoice.
Contact person: the account holder, at the account's email address.
Signature and accession date: the acceptance of the Terms of service on pandorasearch.com, with the date and time the account keeps.

Processor: the company that operates Pandora Search.

Name and address: its identification details (company name, registration and tax details, and address) are provided to anyone with a legitimate interest who asks at info@pandorasearch.com, and appear in the copy the customer requests.
Contact person: info@pandorasearch.com.
Signature and accession date: the publication of these terms as part of the Terms of service, or its representative's signature on the copy the customer requests.

ANNEX II · Description of the processing

Categories of data subjects whose personal data is processed

The natural persons the controller investigates: the holders of the email addresses, aliases, phone numbers, domains, IP addresses, names or photos it enters in the service.
The people who appear in the results: for example, the holders of linked accounts, company officers in business registers or domain holders.

Categories of personal data processed

The starting data the controller enters: email address, alias or username, phone number, domain, IP address, full name and photo.
The results from the sources:
- accounts on online services and their public profile data;
- exposure in known data breaches: the breach's name, its date and the types of data, and never passwords, hashes or other leaked values;
- data from public registers and sources: company officerships, domain and DNS records, certificates and the services an IP address exposes;
- image metadata and search engine results.
The case: its name, the declared purpose and the graph of entities and links.
The audit log of each query: the date, the case's purpose, the transform, the type and value of the data queried and the number of results.

Sensitive data processed (if applicable) and applied restrictions or safeguards

It is not searched for, but the results may reveal it incidentally; for example, a person's account on a service linked to their beliefs. The safeguards:

the service does not query sites of special categories (adult content, dating, health, religion or politics);
it uses no facial recognition and no biometric data: photos are compared by a perceptual hash of the image;
of a breach it shows only the name, the date and the types of data;
the Acceptable use policy prohibits processing, or trying to infer, special categories of data or data on criminal convictions, and investigating minors under 18;
every case requires a declared purpose, which is kept with each query in the audit log;
the processor's staff only look at a case on a credible report of misuse, a request from an authority or a support request from the controller itself.

Nature of the processing

Automated queries to publicly accessible sources and third-party services, on the controller's instructions: the controller launches every transform. The sources are public APIs, open data, official registers, open-source tools and, with the controller's own key, paid services.
Collecting, structuring and storing the results in the controller's case.
Presenting them as a graph, map, timeline, dossier and table.
Exporting them (JSON, CSV and GraphML) and erasing them.
Collection is passive: the person investigated is not notified, and the service does not bypass access controls or anti-bot protections.

Purpose(s) for which the personal data is processed on behalf of the controller

The purpose the controller declares for each case, within what the Terms of service and the Acceptable use policy allow: for example, due diligence, cybersecurity, fraud prevention or verifying information.

Duration of the processing

For as long as the controller's account exists. Results stay in the case until the controller deletes the case or the account. Erasure from the database is immediate, and backups rotate within 14 days.
The sources' answers are kept for at most 24 hours in a cache of each account, so the same query is not repeated. An hourly purge erases anything older.
When the relationship ends (Clause 10(d)), the controller can export its cases before deleting the account.

Processing by (sub-)processors: see Annex IV.

Outside these terms: Pandora Search keeps, as a controller and on its legitimate interest in the security and lawful use of the service, the audit log of each query (the declared purpose, the source, the type and value of the data and the date), to prevent and investigate misuse, as the Privacy policy and the Acceptable use policy explain.

ANNEX III · Technical and organisational measures

Encryption and pseudonymisation

All connections use HTTPS. Cloudflare sits in front in "Full (strict)" mode, with a valid certificate between Cloudflare and the server too, and HSTS of 180 days.
The API keys the controller adds for paid sources are stored encrypted and authenticated, with a key that only exists on the server.
Backups that leave the server are encrypted with a public key. The private key is kept by the operator outside any server.
The internal panel has a read-only profile that sees email addresses and investigation data masked.
Access to that panel by AI tools is read-only and always with the data masked.

Ongoing confidentiality, integrity, availability and resilience

The server is at OVH, in Roubaix (France).
The service runs under its own system user, separate from the other applications on the same server. Only that user can read its data.
Secrets (the service's keys) can only be read by the administrator and the service; they are never in the code.
The application only listens locally, behind nginx, and the server's firewall is active.
There are abuse limits: per-IP limits on the API (at Cloudflare and in the application) and a limit on sign-in codes per hour.

Restoring availability and access

The databases are copied on the server every night, and each copy is kept for 14 days.
Another copy, encrypted, is kept outside OVH for 14 days, checking that the uploaded size matches.
Monitoring warns if a copy is missing or the off-site one is more than 30 hours old.

Regular testing, assessment and evaluation

Automated monitoring checks services, certificates, disk and backups every 5 minutes and alerts the operator.
Every deployment checks that the application starts before replacing the running version.
The code has automated tests: accounts, payments, cache and purges, among others.
These measures are reviewed at least once a year and whenever the service changes significantly.

User identification and authorisation

Customers sign in without a password, with a one-time link or code sent to their email, or with Google. The code is valid for 15 minutes, and sending is rate-limited per hour.
The session is an HttpOnly, Secure, SameSite=Lax cookie, valid for 30 days from the last use.
Each customer sees only their own cases.
The internal panel has two profiles, owner and read-only, with a signed session.
The servers can only be reached by SSH with a key; passwords are disabled.

Protection of data during transmission and storage

TLS end to end, with security headers: HSTS, X-Content-Type-Options, X-Frame-Options, Referrer-Policy and Permissions-Policy.
The sources' cache belongs to each account, so no customer can infer what another has searched for.

Physical security: that of OVH's data centres (Roubaix) and Cloudflare's, as each documents it.

Events logging

Server logs (nginx and system) are kept for 7 days.
Monitoring keeps its alerts.
The audit log keeps every query.

Default configuration

No analytics or advertising cookies unless accepted.
Pandora Search never receives card details.
Breaches are shown without their values.
Paid sources only work with the controller's own key.

Internal IT and IT security governance and management

Only the operator has access to production, and secrets exist only on the server.
Anyone who joins with access to the data commits in writing to confidentiality before getting it.
In an incident, it is contained, its scope is assessed and, if it affects the controller's data, the controller is notified as Clause 9.2 requires.

Certification: none of its own for now.

Data minimisation:

The controller launches every query.
No special-category sites are queried and there is no facial recognition.
Breaches are shown without their values.

Data quality: each result states the source it comes from, so the controller can check it before acting.

Limited data retention

Data	How long it is kept
Cases	Until the controller deletes them
Sources' cache	24 hours
Sign-in codes	About 2 hours
Expired sessions	Purged every hour
Backups	14 days
Server logs	7 days

Accountability: the purpose is declared for every case and kept in the audit log; these terms document the processing.

Data portability and erasure: the controller can export each case as JSON, CSV and GraphML, and delete the case or the account from the application itself, at once.

Assistance to the controller (Clauses 8 and 9)

Requests from data subjects that reach info@pandorasearch.com are passed on to the controller within 5 business days, if it can be identified, and are not answered without its authorisation. The info@ inbox keeps them for 90 days after they are dealt with.
A personal data breach affecting its data is notified to the controller at its account's email address without undue delay and at the latest within 48 hours of becoming aware of it. The notification includes what Clause 9.2 requires.
The processor gives the controller the technical information it needs for its impact assessment.

ANNEX IV · List of sub-processors

This is the agreed list for the general authorisation in Clause 7.7. Changes are announced 30 days in advance, at the account's email address and on this page.

OVH SAS
- Address: 2 rue Kellermann, 59100 Roubaix (France). Contact: the one in its privacy policy.
- Processing: hosting. The servers where the service runs and the cases are stored are in Roubaix.
- Duration: that of the service.
Cloudflare, Inc.
- Address: 101 Townsend St., San Francisco, CA 94107 (United States). Contact: the one in its privacy policy.
- Processing: the content delivery network and security layer in front of the server; requests and responses pass through it encrypted, including the case data the controller sees. It also stores the encrypted backups, which it cannot read.
- Transfer to the United States: the EU-U.S. Data Privacy Framework and the standard contractual clauses in its data processing agreement.
- Duration: that of the service.

The data sources

When a transform runs, the starting data is sent to the source that answers it. There are dozens: public APIs, official registers, search engines, cybersecurity services and, with the controller's own key, paid services. The full list, with their licences, is in the Attributions.

The sources are not sub-processors: they receive the query on the controller's instructions and process their own data as independent controllers, under their own terms. Several are in the United States.