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ONMAKE xTdC

Note on processing of data on the customer's behalf (DPA)

Version 2026-11-04

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1. Scope

In normal use of xTdC, calculation data and projects stay on the user's device and ONMAKE does not receive them: for this data ONMAKE does not act as processor on the customer's behalf and no agreement under Article 28 GDPR is required. Account, subscription, security and support data is processed by ONMAKE as controller, under document 03.

If in a specific case ONMAKE were to receive personal data from the customer to process on its behalf (for example files voluntarily sent for support at the customer's request), the parties would agree in writing instructions, measures, suppliers and retention before processing, and Article 28 GDPR would apply to that processing. The user's transmissions to Editor Ultra (ONMAKE Connect) follow that product's documents.

2. Suppliers and locations

ONMAKE's infrastructure suppliers for the account are: Microsoft Azure (hosting, Italy North region), Supabase (database and authentication, EU Frankfurt region), Aruba (website and email, Italy). The content-delivery network operator jsDelivr is contacted by the user's browser for a stylesheet (document 04); it is not a supplier engaged by ONMAKE.

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