Data processing agreement
pursuant to Art. 28 GDPR · Version 1.0 · Last updated: September 2026
This English version is provided for convenience only. Only the German version is legally binding.
§ 1 Parties and conclusion
The controller (“client”) is whoever sets up Kryst on a Discord server and confirms this agreement during setup with /setup (server operator).
The processor (“contractor”) is Stefan Rohrbach, DMNT Studio, c/o Online-Impressum 10950, Europaring 90, 53757 Sankt Augustin, Germany, email: dmnt-studio@mail.online-impressum.de.
The agreement is concluded by confirmation during /setup (electronic form under Art. 28(9) GDPR). For this purpose, the contractor stores in the record log the Discord ID of the confirming person, the server ID, the time and the agreement version.
§ 2 Subject matter, nature and purpose
The contractor operates Kryst for the client's Discord server and processes personal data of the server members solely to provide the functions activated by the client (e.g. event management, voice channel menu, welcome messages).
Types of data
- Discord user IDs, display names and roles, where a function requires them
- interactions with the bot (commands, button clicks, event sign-ups)
- IDs of channels and roles on the server
Message content is not processed. Should this change (e.g. news module), this agreement will first be amended in a new version and confirmed again.
Data subjects
Members and visitors of the client's Discord server.
Duration
The agreement applies for as long as Kryst is used on the client's server. It ends automatically when the bot is removed from the server or the client terminates it.
§ 3 Instructions
The contractor processes the data only on documented instructions from the client. Instructions are this agreement, the settings the client makes in the bot, and messages to the email address above. If the contractor considers an instruction to be unlawful, it informs the client without delay. Processing outside the instructions takes place only where required by EU or German law; the contractor informs the client beforehand where permitted.
§ 4 Confidentiality
Only the contractor has access to the data. Should the contractor engage other persons in future, it will first commit them to confidentiality in writing.
§ 5 Security of processing
The contractor takes the technical and organisational measures under Art. 32 GDPR described in Annex 1. It may develop them further as long as the level of protection does not decrease.
§ 6 Sub-processors
The client consents to the use of the sub-processors listed in Annex 2. The contractor announces new or replacement sub-processors at least 14 days in advance on this page and in the support channel. The client may object within this period; if no agreement is reached, the client may terminate the agreement with immediate effect. The contractor contractually binds sub-processors to the same data protection obligations.
Discord is not a sub-processor of the contractor. The client operates its server on Discord itself and has its own contractual relationship with Discord for this purpose.
§ 7 Assistance to the client
The contractor assists the client to a reasonable extent
- with requests from data subjects (access, erasure, etc.) by providing or deleting the data stored for a Discord ID within 14 days,
- with the security of processing, notifications of personal data breaches and data protection impact assessments (Art. 32 to 36 GDPR).
If the contractor receives a request directly from a data subject, it forwards it to the client.
§ 8 Personal data breaches
If the contractor becomes aware of a personal data breach, it informs the client without delay, and no later than within 48 hours, via the channel specified by the client during /setup or by Discord direct message to the person who confirmed the agreement. The notification contains, as far as known, the nature of the breach, the data concerned, likely consequences and the measures taken.
§ 9 Deletion after termination
After the end of the agreement, the contractor deletes all data processed on behalf of the client within 30 days. Backups are overwritten in the regular 14-day cycle. On request, the contractor provides the client with a copy of the server settings before deletion. The record log under § 1 is retained because the contractor uses it to fulfil its own accountability obligations (three years after the end of the agreement).
§ 10 Evidence and audits
On request, the contractor provides the client with the information necessary to demonstrate compliance with the obligations under Art. 28 GDPR. On-site audits are possible with reasonable notice; given the small scale of the service, they are primarily carried out in writing.
§ 11 Liability and final provisions
Liability is governed by Art. 82 GDPR. German law applies. Should any provision be invalid, the remainder of the agreement remains valid. Changes to this agreement receive a new version number and are confirmed again by the client in the bot.
Annex 1 – Technical and organisational measures
- Location: a rented server of Contabo GmbH in a data centre in the European Union (Lauterbourg, France). Physical access and power supply are the responsibility of the data centre.
- Server access: only the contractor, via an encrypted SSH connection. Login only with a cryptographic key; password login is disabled.
- Separation: bot, database and website run in separate Docker containers in their own isolated network. The database cannot be reached from outside.
- Credentials: passwords and tokens are stored in configuration files on the server, not in the source code.
- Transmission: website only via HTTPS (TLS). The bot communicates with Discord exclusively in encrypted form.
- Data minimisation: no message content; people in logs only as a Discord ID; error logs no longer than 30 days.
- Separation of customers: all data is assigned to the respective server ID; commands only affect the own server.
- Availability: daily database backup, retained for 14 days.
- Changes: new versions run on a test server first.
Annex 2 – Sub-processors
- Contabo GmbH, Welfenstraße 22, 81541 Munich, Germany · hosting of server and database
- Contabo France SAS, 2 rue Taunus, 67630 Lauterbourg, France · operation of the data centre (sub-processor of Contabo GmbH)