Data processing agreement (template)

• The customer, controller: [to be filled in at signing : company name, address and UID of the customer]
• Antisy, processor: Antisy Sàrl, Esplanade de Pont-Rouge 2, 1212 Grand-Lancy (canton of Geneva, Switzerland), business identification number (UID) CHE-240.303.672

Antisy processes, on behalf of the customer, data of visitors to the sites that the customer protects with the product. The customer remains the controller; Antisy acts as a processor.

To tell human visitors from automated programs on the customer’s forms and sign-ins, for the security of its site. No other purpose, in particular no advertising purpose.

Visitors to the customer’s sites. Data processed:

• what the script measures in the browser: the capabilities the browser declares, the languages and the time zone of the browser, the graphics rendering and the fingerprint of the device, signs of automation, the behaviour of the JavaScript engine and the course of the interaction; the fingerprint as digests salted per site, the interaction as counters and aggregates, without the content of the keystrokes or of the fields;
• what Antisy’s server reads from the request: the order of the HTTP headers, the IP address, the User-Agent and the request context;
• for a sign-in or a sign-up, the account identifier that the site passes on, encrypted and hashed;
• the result of the verification (verdict, score, reasons).

• Personal fields encrypted at rest, with the keys able to be destroyed.
• Browser measurements sent in an encrypted envelope.
• Database roles with limited privileges; database installed on the API’s server, which reaches it without leaving the machine; a connection over the network is accepted only over verified TLS.

• Access to visitor data limited to the people who need it, bound to confidentiality; to date, only Antisy’s managing director has access to it.
• Administration log of operating actions.
• No external penetration test has taken place yet; one is planned after the pilot.

Antisy hosts the data in Geneva, Switzerland, at Infomaniak; the hosting has been in service since 27 October 2026.

• Authorised sub-processor: Infomaniak, in Geneva, Switzerland, for the hosting of the servers and of the database, the storage of the backups, and the messaging used for Antisy’s technical alerts, which carry no visitor data.
• Receive no visitor data: GitHub (code and continuous integration), PostHog (audience measurement of the antisy.com showcase), Hostinger (web space of the static showcase).
• Antisy discloses no visitor data outside Switzerland without the customer’s prior written authorisation, nor to a country that does not ensure an adequate level of protection. It informs the customer in writing 30 days before any addition or replacement of a sub-processor.

The customer informs its visitors: its privacy policy describes the processing and names Antisy. Model text to insert there, to be adapted by the customer and to be validated:

Protection against bots. To protect its forms against bots, [to be filled in at signing : name of the site] uses Antisy Sàrl (Switzerland), its processor. When you fill in a form, your browser sends technical measurements of your device and of the course of your interaction with the page directly to Antisy (counters, without the content of your keystrokes or of your fields), with your IP address and the identification of your browser. [to be filled in at signing : name of the site] does not receive these measurements. They are kept encrypted for a few minutes, the time it takes to verify your submission, then deleted [to be filled in at signing : variant if keeping the measurements is switched on for this site (it is off by default): “then deleted” becomes “then deleted, except a part (the graphics rendering, the graphics processor, the behaviour of the JavaScript engine and the signs of automation), kept encrypted for 30 days”]. The IP address, the identification of the browser and the context of the request are erased from the record after 30 days; the sign-in identifier and the outcome after 90 days; the result of the verification is kept for 180 days at most. These data are not used for advertising. To exercise your rights (access, rectification, erasure), write to [to be filled in at signing : contact of the site].

Antisy assists the customer in answering requests for access, rectification and erasure. After 90 days, a record no longer carries the sign-in identifier or the address: it can no longer be found from either of them.

If a person contacts Antisy directly, Antisy does not answer on the substance: it forwards the request to the customer within 5 working days and tells the person to contact the customer. At the customer’s written request, Antisy searches for, exports or erases the data relating to a specific attempt, within 10 working days of the request, from the event identifier that the customer provides.

• Antisy processes the data only on documented instructions from the customer: this agreement, its settings in the dashboard and its written requests to support@antisy.com. It informs the customer immediately if it considers that an instruction infringes data protection.
• The authorised staff are bound to confidentiality, by undertaking or by law; to date, only Antisy’s managing director has access to visitor data. This obligation survives the end of the agreement.
• Antisy sends no visitor data to an artificial intelligence service or to a third-party tool.
• Antisy notifies the customer of any breach of data security that concerns it within 48 hours of its discovery.

The customer, or an auditor bound to secrecy whom it appoints, may check that this agreement is observed once a year, with 30 days’ notice, during business hours, at the customer’s expense, by examination of documents and then, if that is not enough, by interview. The check includes neither a penetration test without written consent, nor access to the source code, to the detection rules or to the data of other customers.

Pilot: the customer’s data are erased 30 days after the end of the pilot, or returned first if the customer asks for it in writing before the end. End of an agreement outside the pilot: on written request within the 30 days following the end, the data are returned in a readable format; they are erased 90 days after the end of the agreement (the backups, when they expire). Antisy confirms the erasure in writing on request.

Antisy accepts customers established in the European Union. The data are processed at Infomaniak, in Geneva; the European Commission recognises Switzerland as offering an adequate level of protection. This agreement is offered on every tier, including the Free tier, and it is written to meet Article 28 of the GDPR too where the customer is subject to it. Antisy has not designated a representative in the European Union (GDPR, Art. 27).

Swiss law. Prices in CHF, excluding VAT, according to the general terms and conditions. Antisy’s liability is limited to wilful misconduct and gross negligence. The ordinary courts of the canton of Geneva have exclusive jurisdiction.

[to be filled in at signing : place, date and signatories of both parties]