Data Processing Addendum

Effective date: October 24, 2026

This Data Processing Addendum (“Addendum”) forms part of the Terms of Service between you (“you”, the customer) and JS Designs (“we”, “us”, “our”) for Stelld (“the Service”). It applies to every account, on every plan, including the free plan, and needs no separate signature.

1. Roles and Scope

This Addendum covers the personal information that people submit through your forms (“Respondent Data”). You decide what your forms collect and why, and you are responsible for that information. We handle Respondent Data only as your service provider, on your behalf. Our handling of your own account information is described in our Privacy Policy.

This Addendum is written to meet the requirements for service providers under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec’s Act respecting the protection of personal information in the private sector, including section 18.3.

2. Purpose Limitation

  • We use Respondent Data only to provide the Service to you: to store it, display it to the members of your account, export it, and notify you that a response arrived.
  • We do not sell Respondent Data, use it for advertising or profiling, or share it with anyone except the providers listed in section 5.
  • We do not read Respondent Data except where you ask us to for support, or where it is necessary to investigate a security incident or to comply with the law.

3. Security Measures

  • Each submission is encrypted before it is stored, with data keys unique to your account. Those keys are wrapped by a key service hosted separately from the database, in Montréal, by VEXXHOST, a Canadian-owned provider. The database and its backups hold only encrypted submissions and wrapped keys.
  • Our application servers decrypt a submission only in memory, at the moment an authorized member of your account views or exports it.
  • All connections to the Service use TLS 1.2 or later.
  • Passwords are stored as bcrypt hashes. Access to our infrastructure is limited to the people who operate the Service, each bound by confidentiality.
  • Notification emails never contain response content. No analytics or tracking scripts run on the Service, including on the forms your respondents fill in.

4. Location

Respondent Data is stored and processed in Canada, on Amazon Web Services in the ca‑central‑1 region (Montréal, Quebec), and its backups remain there. We do not send Respondent Data outside Canada.

5. Sub-processors

The following providers handle Respondent Data on our behalf:

  • Amazon Web Services — hosting, database and backups, in Montréal.
  • VEXXHOST — the key service that holds your account’s encryption keys, in Montréal. It never receives Respondent Data itself.

Our email provider (Resend) and payment processor (Stripe) do not receive Respondent Data. We will give you at least 30 days’ notice by email before adding or replacing a provider that handles Respondent Data. If you object, you may delete your forms or your account before the change takes effect.

6. Confidentiality Incidents

A confidentiality incident is any access to, use or communication of Respondent Data that is not authorized by law, its loss, or any other breach of its protection.

  • If we become aware of a confidentiality incident affecting your Respondent Data, we will notify you by email without undue delay, and in any case within 72 hours.
  • The notice will describe what happened, the information involved, the steps we have taken and the contact person, and we will update it as we learn more.
  • We will help you assess whether the incident presents a risk of serious injury and, where it does, to notify the Commission d’accès à l’information du Québec, the Office of the Privacy Commissioner of Canada and the people concerned.
  • We keep a register of confidentiality incidents.

7. Requests from Individuals

If a respondent asks us to access, correct or delete their information, we will refer them to you and will not respond on your behalf. You can view, export (CSV) and delete individual responses from your dashboard at any time.

8. Legal Demands

If a court or public authority demands Respondent Data from us, we will notify you before disclosing it, unless the law prohibits us from doing so, and will disclose only what the demand legally requires.

9. Retention and Deletion

We keep Respondent Data for as long as you keep it in the Service. When you delete a response, a form or your account, the data is removed from the live database immediately, and encrypted copies in our automated backups are permanently deleted within 7 days. When your account ends, we keep no Respondent Data beyond that period.

10. Your Responsibilities

  • You are responsible for collecting only the information you need, for informing your respondents and obtaining any consent the law requires, and for deciding whether the Service is appropriate for the information you collect, including sensitive information such as health information.
  • You are responsible for who has access to your account and for keeping its credentials secure.

11. General

If this Addendum conflicts with the Terms of Service on the handling of Respondent Data, this Addendum prevails. Otherwise, the Terms of Service apply. We may update this Addendum as described in the Terms of Service, and will not reduce the protection it gives Respondent Data without notifying you by email in advance.

12. Contact

Questions about this Addendum may be directed to our person in charge of the protection of personal information, Jack So, at info@stelld.ca.