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GDPR Addendum · Effective April 13, 2026

EU data protection commitments under GDPR.

Supplements the DPA with GDPR-specific commitments. Lawful basis matrix, data subject rights mapping, Standard Contractual Clauses, supervisory authority and DPIA approach. Applies automatically when GDPR is engaged.

GDPR Addendum key facts

7Data subject rights
2021/914SCC version
N/AEU representative needed
UK ICOLead supervisory authority
30dDSAR response window
Section 01
// When this Addendum applies

Scope of this Addendum

This Addendum applies whenever Crawlux processes personal data subject to GDPR or UK GDPR. Where this Addendum and the base Privacy Policy or DPA conflict on GDPR matters, this Addendum prevails for the GDPR-regulated processing.

01

Territorial scope

Applies when Crawlux processes personal data of individuals in the EEA or UK, regardless of where the customer is established. The scope follows GDPR Article 3 and UK GDPR equivalent provisions.

02

Material scope

Applies to all personal data Crawlux processes: customer account data, audited domain content where it contains personal data, AI engine query logs and any other processing within the audit pipeline.

Why this Addendum exists

The DPA covers processor obligations generally. This Addendum spells out GDPR-specific commitments that supplement those obligations: lawful basis matrix, the seven data subject rights, SCCs incorporated by reference, supervisory authority and DPIA process.

Section 02
// Article 6 lawful basis

Lawful basis matrix

Lawful basis for each Crawlux-side processing activity. Customer-side processing (the audited domain content) is the customer's responsibility as controller. The matrix below covers what Crawlux processes on its own initiative.

Processing activityLawful basisType
Service delivery (audit execution)Contract Art. 6(1)(b)Mandatory
Account management and billingContract Art. 6(1)(b)Mandatory
Methodology improvement (aggregated data)Legitimate interest Art. 6(1)(f)Mandatory
Security and fraud preventionLegitimate interest Art. 6(1)(f)Mandatory
Legal obligation (tax, accounting)Legal obligation Art. 6(1)(c)Mandatory
Service status notificationsLegitimate interest Art. 6(1)(f)Mandatory
Marketing emails (newsletter, product)Consent Art. 6(1)(a)Optional
Analytics cookiesConsent Art. 6(1)(a)Optional

Customer-side lawful basis

When the customer submits audited content containing personal data, the customer determines and documents the lawful basis for that processing. Common bases for SEO audit context: legitimate interest in measuring website performance and consent for tracking-related elements.

Section 03
// Articles 15-22

Data subject rights matrix

The seven GDPR data subject rights and how they map to Crawlux processing. Account holders exercise these rights via [email protected]. Data subjects of customer content go through the customer (controller) directly.

RightArticleCrawlux response
Right of accessArt. 15Account data exported via dashboard or API. 30-day response for complex requests.
Right to rectificationArt. 16Account profile editable directly. Other data corrected on request within 30 days.
Right to erasureArt. 17Account deletion via dashboard. Data deleted from production within 14 days, backups within 90 days.
Right to restrict processingArt. 18Processing pause requested via [email protected]. Implemented within 5 business days.
Right to data portabilityArt. 20Account and audit data exported in JSON via API. PDF reports also available. Self-service.
Right to objectArt. 21Marketing objection via one-click unsubscribe. Other processing objections via [email protected].
Right against automated decisionsArt. 22Crawlux audits do not produce decisions with legal effect. Output is informational. Not in scope.
Section 04
// Chapter V transfers

International transfers

Personal data may flow to subprocessors outside the EEA and UK. The Standard Contractual Clauses adopted by EU Commission Decision 2021/914 govern these transfers. The UK Addendum applies for transfers from the UK.

EU SCCs

Module Two: Controller to Processor

EU Commission Decision 2021/914 Module Two SCCs apply when an EEA controller transfers personal data to a non-EEA processor or sub-processor. Incorporated by reference in this Addendum.

UK Addendum

UK Addendum to EU SCCs

UK ICO International Data Transfer Addendum applies to transfers originating from the UK. Forms a complete UK-compatible transfer mechanism when combined with the EU SCCs.

TIA

Transfer impact assessments

Each non-adequate destination is assessed for local law impact on SCC protections. Supplementary measures applied where TIA identifies gaps. Encryption and contractual safeguards form the baseline measure set.

Some subprocessor destinations have adequacy decisions in place under GDPR Chapter V. For these, SCCs are not strictly required but are still applied as belt-and-suspenders contractual protection. Current adequacy applies to: UK (under EU adequacy decision), Switzerland, Israel and Japan among others.

Section 05
// Articles 30 and 35

DPIAs and records of processing

GDPR requires data protection impact assessments for high-risk processing and records of processing activities for organizations meeting Article 30 thresholds. Crawlux maintains both.

Art. 35

DPIA approach

Standard Crawlux audit processing has been assessed as not high-risk under DPIA criteria. Fresh DPIAs are conducted when new features introduce automated decision-making, large-scale special category processing or other Article 35 trigger conditions.

Art. 30

Records of processing activities

Crawlux maintains an Article 30 ROPA covering processing purposes, categories of data subjects, categories of personal data, recipients, retention periods and security measures. Available to supervisory authorities on request.

Customers can request a summary of the standard processing DPIA for inclusion in their own DPIA workflow. Summary is provided under NDA via [email protected]. Full DPIA documentation is internal due to security-sensitive content.

Section 06
// Articles 27, 37 and 56

Supervisory authority, DPO and EU representative

Identifying the regulators, the DPO contact and whether an Article 27 EU representative is required.

Lead

UK Information Commissioner's Office

The lead supervisory authority for Crawlux is the UK ICO given the London primary office. Contact: ico.org.uk. EEA-based data subjects can also contact their local supervisory authority for matters about their own data.

DPO

Data protection contact

A formal Article 37 DPO is not currently required as Crawlux processing does not meet the mandatory DPO triggers. The privacy team operates as the data protection contact: [email protected]. This is reviewed annually.

Art. 27

EU representative status

Crawlux operates from London which provides EEA-equivalent jurisdiction under the UK-EU adequacy framework. Article 27 EU representative is therefore not currently required. If adequacy or office structure changes, an EU representative will be appointed.

Section 07
// 2002/58/EC and PECR

ePrivacy and electronic communications

The ePrivacy Directive and the UK Privacy and Electronic Communications Regulations apply alongside GDPR for cookies and direct marketing communications. Crawlux compliance is documented in dedicated policies.

Cookies

ePrivacy cookie compliance

Strictly necessary cookies set automatically per ePrivacy exemption. Analytics and other cookies require prior consent via the Crawlux consent banner. Full inventory in the cookie policy.

Email

ePrivacy email marketing compliance

Marketing email requires opt-in consent. Soft opt-in applies to existing customers for similar products. One-click unsubscribe in every marketing email. Full procedures in the anti-spam policy.

// GDPR Addendum FAQ

Common GDPR questions

Six questions covering Addendum scope, lawful basis, exercising rights, EU representation, supervisory authority and DPIAs.

When does GDPR apply to my Crawlux usage?

GDPR applies whenever Crawlux processes personal data of individuals located in the EEA or UK. This is the case for nearly every Crawlux customer because audited domains often contain references to EEA residents (authors, contacts, team members). The Addendum applies automatically; no separate opt-in is needed.

What is Crawlux's lawful basis for processing?

Crawlux as the processor relies on the customer's lawful basis. The customer (controller) determines and documents the lawful basis. For Crawlux's own processing of customer account data, the lawful basis is contract performance for service delivery and legitimate interest for service improvement. Marketing requires consent.

How do I exercise my data subject rights?

If you are a data subject of customer data, contact the customer (controller) directly. If you are a Crawlux account holder requesting your own data, email [email protected]. We will respond within 30 days per GDPR Article 12. Available rights include access, rectification, erasure, restriction, portability and objection.

Do you have an EU representative?

Crawlux operates from London, an EEA-equivalent jurisdiction under the UK GDPR with adequacy in place. The London office handles EEA-related matters, which means an Article 27 EU representative is not currently required. If this changes, an EU representative will be appointed and disclosed in this addendum.

Who is your supervisory authority?

The lead supervisory authority for Crawlux is the UK Information Commissioner's Office (ICO) given the London primary office. EEA-based data subjects can also contact their local supervisory authority for matters concerning their personal data. Contact details for both are in section 6 of this addendum.

Do you conduct DPIAs?

Yes, where Article 35 thresholds are met. The standard Crawlux audit processing has been assessed as not high-risk under DPIA criteria. New features that introduce automated decision-making or large-scale special category processing trigger fresh DPIAs. Customers can request the DPIA summary for their own DPIA workflow under NDA.

GDPR inquiries
// Contact

GDPR contact

Data subject requests, GDPR-specific questions, lawful basis clarifications and any other GDPR matter goes to the privacy team.

For DPA contractual matters, see the Data Processing Agreement. For privacy-specific questions, see the privacy policy. For security questions, see the security policy.

Read the full DPA next

The DPA covers the broader processor obligations: subprocessors, security measures, breach notification, audit rights and termination procedures.

GDPR Addendum v1.0 · Effective April 13, 2026 · Lead: UK ICO · 30-day DSAR response