Data Processing Addendum (DPA)

Last Updated: January 15, 2026

1. Scope and Applicability

This Data Processing Addendum (“Addendum”) is incorporated into the Terms of Service of Data Migration Tools, a utility suite owned and operated by Yin Yang Inc. d/b/a ClonePartner.

This Addendum applies to any user (“Customer”) who processes Personal Data subject to GDPR, UK GDPR, CCPA, or other applicable data protection laws using the server-side features of the Data Migration Tools site.

2. Incorporation of Master DPA

By using the Data Migration Tools, the Customer agrees that the ClonePartner Master Data Processing Agreement (available at https://clonepartner.com/dpa) is legally incorporated into this session by reference, subject to the Specific Modifications defined in Section 3 below.

This structure allows free utility users to benefit from the same robust legal framework as our enterprise consulting clients without requiring a signed manual contract.

3. Specific Modifications for Free Utilities

For the purposes of this specific Site, the Master DPA is modified as follows:

  • A. Definition of “Service”: The term “Service” shall refer specifically to the self-serve data validation, conversion, and schema mapping utilities provided on data-migration-tools.com.
  • B. Definition of “Order Form”: Since this is a free service, any reference to an “Order Form” or “Statement of Work” in the Master DPA shall be interpreted as the User’s active session and the specific data processing action (e.g., “Convert File”) initiated by the User.
  • C. Service Term & Termination: The “Term” of data processing is defined as ephemeral. The processing relationship begins when the User initiates an upload and ends immediately upon the completion of the file processing and the subsequent cryptographic purging of data from volatile memory.
  • D. Sub-Processors: The User acknowledges that for specific server-side utilities, ClonePartner may utilize the same trusted sub-processors (e.g., AWS, Google Cloud) listed in our Master DPA to perform compute functions.

4. International Data Transfers

ClonePartner processes data in secure facilities that may be located outside of your country of origin. We rely on the EU Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum included in our Master DPA to validate these transfers.

5. Contact for Compliance

For specific inquiries regarding data privacy or to audit our compliance certifications (SOC 2 Type II / ISO 27001), please contact our Data Protection Officer (DPO):

Yin Yang Inc. d/b/a ClonePartner Attn: Privacy Team 9450 SW Gemini Drive Beaverton, Oregon 97008 Email: legal@clonepartner.com