Data Processing Addendum
How we process personal data on your behalf as your processor.
Last updated: 2026-10-12
This document may be updated from time to time; material changes are announced in the console.
Roles
- For personal data in your managed tenants, you (the MSP) are the controller (or processor for your end-customers) and rugged.sh, operated by Rugged Technology Services Inc. (New Brunswick, Canada), is your processor. We process that data only on your documented instructions.
- For your own MSP account data, we act as controller for the limited purpose of providing, securing, and billing the service.
Scope of processing
- Subject matter: providing the rugged.sh control plane. Duration: for the term of your agreement plus any legally required retention.
- Nature and purpose: deploying, governing, and optimizing Microsoft cloud across your customer tenants on your instruction.
- Data subjects and data types: your team members and your end-customers' directory users; identifiers, role and configuration data, and operational metadata. We do not process special-category data for these purposes.
Our commitments
- Confidentiality: personnel with access are bound by confidentiality obligations.
- Security: we apply technical and organizational measures appropriate to the risk, including hard tenant isolation, encryption of secrets in Azure Key Vault, least-privilege app-only access, and an audit trail.
- Assistance: we help you respond to data-subject requests and to meet your security, breach-notification, and impact-assessment obligations.
Sub-processors
We engage a limited set of sub-processors to deliver the service. Each is bound by data-protection terms consistent with this addendum:
- Microsoft Azure: infrastructure, managed PostgreSQL hosting and backup, secret management, and the Microsoft cloud platform your tenants run on. Control-plane data resides in Canada Central and its backups do not leave the Azure tenant.
- Stripe: payment processing and tax calculation, limited to billing contact details, billing address, and tax identifiers.
- Cloudflare: content delivery, DNS, edge security, and outbound transactional email.
- Anthropic: AI model provider for the optional AI features (the operator assistant and screening of marketplace submissions), used only if those features are enabled for your account, and limited to the content being processed. When they are not enabled, nothing is sent to a model provider.
- Sentry: error monitoring, used only if enabled for the platform, limited to error reports (request method and path and a technical stack trace).
- We maintain a current sub-processor list and give reasonable prior notice of additions or replacements so you can object.
Audits and records
- We maintain records of the processing we carry out on your behalf and make available the information reasonably necessary to demonstrate compliance with this addendum.
- Where you require an audit beyond that documentation, we will make reasonable information available on request, no more than once every 12 months absent a legal or regulatory requirement to do so more often, under confidentiality and in a way that does not disrupt the security of other customers.
International transfers, breach, deletion
- Where personal data is transferred across borders, we rely on a lawful transfer mechanism recognized under applicable data protection law, such as Standard Contractual Clauses, which are incorporated into this addendum by reference and apply automatically where required.
- We will notify you without undue delay after becoming aware of a personal-data breach affecting your data.
- On termination, after the 90-day recovery window described in the Terms, we delete or return your personal data from live systems, subject to legally required retention. Encrypted backups are not edited in place: they expire on their own schedule, within 35 days for point-in-time backups and within three months for weekly backups held in a geo-redundant vault. Until they expire they are not used for any purpose other than disaster recovery.