JaSMS

Data Processing Terms

Version 2026-10-12 · 12 October 2026 · GDPR Article 28

These terms apply when we process personal data on your behalf, and form part of the Terms of Service. They are the written agreement Article 28(3) requires. If your procurement needs a signed copy on your own paper, email support@jasms.dk.

1. Roles

You are the controller. LynBro ApS is the processor. You decide who is messaged and what they are told; we deliver it. We do not choose recipients, write content, or use either for our own purposes.

2. Subject matter and duration

Delivering messages you submit, for as long as you have an account, plus the retention periods in the Privacy Policy.

3. Nature and purpose

Receiving, queueing, routing and transmitting messages; recording delivery outcomes; billing you for it.

4. Categories of data and data subjects

  • Data subjects: the people you message, and the contacts you store in the portal.
  • Data: mobile number, message content, delivery status and timing, plus whatever you choose to store on a contact record.
  • Special categories: none are needed, and none should be sent. If your use case involves health, religious or similar data, speak to us before you start — the standard terms are not written for it.

5. Our obligations

  1. Process only on your documented instructions. Using the service is an instruction. If we believe an instruction breaks the GDPR, we will say so rather than carry it out silently.
  2. Keep everyone with access under a duty of confidentiality.
  3. Apply the Article 32 measures listed in the Privacy Policy.
  4. Help you answer data subject requests, and help with impact assessments and consultations, so far as is reasonable.
  5. Tell you without undue delay if we become aware of a breach affecting your data, with what we know at the time rather than waiting until we know everything.
  6. On the end of the agreement, delete or return the data, except what law requires us to keep.
  7. Make available what you need to verify our compliance, and allow an audit on reasonable notice, no more than once a year unless a breach or a regulator makes another necessary.

6. Sub-processors

You give general authorisation for the sub-processors listed in the Privacy Policy. We will give notice before adding or replacing one, and you may object on reasonable data-protection grounds; if we cannot resolve the objection, you may terminate the affected service without penalty. Each sub-processor is bound by terms no less protective than these, and we remain liable for what they do.

7. Transfers outside the EU

The service runs in the EU. Delivering a message to a network outside the EU necessarily transfers the destination number and the content to that network — that is inherent in sending an SMS abroad, and by submitting such a message you instruct us to make that transfer. Sub-processor transfers rely on the Standard Contractual Clauses.

8. Your obligations

  1. Have a lawful basis for messaging every recipient, and be able to show it.
  2. Give the privacy information your own recipients are entitled to.
  3. Do not submit data you have no right to process, and do not use the service in a way that puts us in breach.
  4. Honour objections and unsubscribes. We provide the mechanism; acting on it is yours.

9. Liability

Clause 8 of the Terms of Service applies to these terms, except where the GDPR provides otherwise for claims by data subjects or regulators.

LynBro ApS · CVR 46321499 · Denmark · support@jasms.dk
Version 2026-10-12 · last updated 12 October 2026. English is the governing version of these documents.