This Data Processing Agreement (the “DPA”), entered into by the WuBook customer identified on the applicable WuBook ordering document for WuBook services (“Customer”) and the WuBook company identified on the ordering document (“WuBook”), governs the processing of personal data that Customer uploads or otherwise provides WuBook in connection with the services connected.

This DPA is incorporated into the relevant WuBook services agreement attached to or incorporated by reference into the ordering document previously executed by Customer, referred to generically in this DPA as the “WuBook Contract”. Collectively, the DPA (including the SCCs, as defined herein), the WuBook Contract, and the applicable ordering documents are referred to in this DPA as the “Agreement”. In the event of any conflict or inconsistency between any of the terms of the Agreement, the provisions of the following documents (in order of precedence) shall prevail:


“Controller-to-Controller SCCs” means the Standard Contractual Clauses (Controller to Controller Transfers - Set II) in the Annex to the European Commission Decision of December 27, 2004, as may be amended or replaced from time to time by the European Commission.

“Controller-to-Processor SCCs” means the Standard Contractual Clauses (Processors) in the Annex to the European Commission Decision of February 5, 2010, as may be amended or replaced from time to time by the European Commission.

“Customer Personal Data” means Personal Data:

“Data Controller” means Customer.

“Data Processor” means WuBook.

“Data Protection Requirements” means the Directive, the General Data Protection Regulation, Local Data Protection Laws, any subordinate legislation and regulation implementing the General Data Protection Regulation, and all Privacy Laws.

“Directive” means the EU Data Protection Directive 95/46/EC (as amended).

“EU Personal Data” means Personal Data the sharing of which pursuant to this Agreement is regulated by the Directive, the General Data Protection Regulation and Local Data Protection Laws.

“General Data Protection Regulation” means the European Union Regulation on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

“Local Data Protection Laws” means any subordinate legislation and regulation implementing the Directive or the General Data Protection Regulation which may apply to the Agreement.

“Personal Data” means information about an individual that:

“Personal Data Breach” means any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Customer Personal Data.

“Privacy Laws” means all applicable laws, regulations, and other legal requirements relating to:

“Process” and its cognates mean any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.   

“SCCs” means all Controller-to-Processor SCCs and Controller-to-Controller SCCs entered into between the parties under the Agreement.

“Subprocessor” means any entity which provides processing services to WuBook in furtherance of WuBook’s processing on behalf of Customer.

“Supervisory Authority” means an independent public authority which is established by a European Union member state pursuant to Article 51 of the General Data Protection Regulation.


Each party agrees to process Personal Data received under the Agreement only for the purposes set forth in the Agreement. For the avoidance of doubt, the categories of Personal Data processed and the categories of data subjects subject to this DPA are described in Appendix 1 to this DPA.


The parties shall each comply with their respective obligations under all applicable Data Protection Requirements.


Customer agrees to:




The parties agree that on the termination of the data processing services or upon Customer’s reasonable request, WuBook shall, and shall cause any Subprocessors to, at the choice of Customer, return all the Customer Personal Data and copies of such data to Customer or securely destroy them and demonstrate to the satisfaction of Customer that it has taken such measures, unless Data Protection Requirements prevent WuBook from returning or destroying all or part of the Customer Personal Data disclosed. In such case, WuBook agrees to preserve the confidentiality of the Customer Personal Data retained by it and that it will only actively process such Customer Personal Data after such date in order to comply with applicable laws.


Customer acknowledges that in the provision of some services (such as PMS and CRM), WuBook, on receipt of instructions from Customer, may transfer Customer Personal Data to and otherwise interact with third party data processors.

Customer agrees that if and to the extent such transfers occur, Customer is responsible for entering into separate contractual arrangements with such third party data processors binding them to comply with obligations in accordance with Data Protection Requirements.

For avoidance of doubt, such third party data processors are not Subprocessors.


This DPA shall remain in effect as long as WuBook carries out Personal Data processing operations on behalf of Customer or until the termination of the WuBook Contract (and all Personal Data has been returned or deleted in accordance with Section 8 above).


Notwithstanding anything in the Agreement to the contrary, this DPA shall be governed by the laws of Italy, and any action or proceeding related to this DPA (including those arising from non contractual disputes or claims) will be brought in the Court of Pesaro, Italy.

11. Subprocessors

13. Contact Information.

Contact points for data protection enquiries:

Data importer: Signatory to the Agreement between the parties  

Data exporter: Signatory to the Agreement between the parties

WuBook S.R.L © 2018

Appendix 1: Personal data and data subjects

Personal data

Data Processor shall process the personal data below under the supervision of Data Controller, as specified in article 1 of the Data Processing Agreement:

Of the following categories of parties involved:

Data Controller represents and warrants that the description of personal data and categories of data subjects in this Appendix 1 is complete and accurate, and shall indemnify and hold harmless Process for all faults and claims that may arise from a violation of this representation and warranty.