Part of the service agreement. Draft for review by counsel. Last updated 10 November 2026.
The client is the personal information controller for the data in its books (customers, suppliers, employees, TINs, addresses, amounts). MCRC is the personal information processor and acts only on the client's documented instructions, which include the operation of the service as described on the website and in the runbooks.
Hosting (Contabo GmbH, Singapore and Germany regions, or another provider named in the order form), email delivery (MCRC's own mail server), off-site backup storage (an object storage bucket named in the order form). Changes are announced 30 days ahead.
Encryption in transit and of backups, key escrow shared with the client, two-factor sign-in, role-based access, separate sites per client, daily integrity checks of the audit log, encrypted off-site copies, and the deletion procedure in the offboarding runbook.
MCRC notifies the client without undue delay and within 72 hours of becoming aware of a personal data breach, with what is known at the time, so the client can meet its own obligations to the National Privacy Commission and the data subjects.
MCRC helps the client answer data subject requests that concern data in the system, and provides the information reasonably needed for the client's privacy impact assessments and registrations.
At the end of the service MCRC returns the data as a complete export and then deletes it, confirmed by a certificate of deletion, except for records MCRC must keep under its own professional obligations, which are kept only for that purpose and that period.
The client may ask once a year for the evidence of these measures (backup logs, restore test logs, access lists) and, with reasonable notice, for an audit by an independent party bound by confidentiality.
Sentire Ledger