Legal · DPA v1.0-beta · 12 October 2026
Data Processing Addendum
This DPA is part of every Lilo agreement — it is incorporated by reference into the Beta Agreement, so it is already in force the moment a workspace is created. We will countersign your own copy on request: hello@angilabs.com.
Plain-language version, v1.0-beta. A qualified legal review is scheduled before general availability; if that review changes anything, the change log at the bottom will say exactly what and when.
1. Roles
- For device telemetry an MSP connects: the MSP’s end-client is the controller, the MSP is the processor, and AngiLabs is a sub-processor. For an internal IT team’s own fleet, AngiLabs processes directly for that customer.
- For the customer’s own account data (company, user emails, billing, usage), AngiLabs is the controller, as the Privacy Policy describes.
- The customer warrants it has the authority and lawful basis for the telemetry it connects — including, for MSPs, that end-client agreements permit this processing.
2. What we process, and only on your instructions
- Data: device inventory and telemetry (hostnames, models, serials, health signals, alert history), the identifiers that come with them, and workspace user accounts. Data subjects: your staff and, for MSPs, your end-clients’ staff.
- Purpose: operating Lilo for your workspace — scoring, lifecycle planning, reporting. Nothing else. We process only on your documented instructions (using the product is the instruction), never for advertising, profiling or resale.
- Confidentiality: everyone with access is bound by confidentiality obligations.
3. Security measures
- Tenant isolation enforced at the database layer (PostgreSQL row-level security, enabled and forced, with the application role unable to bypass it).
- TLS in transit; integration credentials and 2FA secrets encrypted at rest; 12-character minimum passwords; authenticator-app 2FA; account lockout.
- Support access to a workspace only through customer-granted, time-boxed, scoped permission — read-only by default, every action logged with dual attribution, revocable live.
- Append-only audit and consent logs; administrative access is MFA-gated and logged.
4. Sub-processors
- Current list: angilabs.com/legal/subprocessors. You authorize that list generally.
- We give 30 days’ notice before adding or changing a sub-processor (via the email on your account); you may object on reasonable data-protection grounds, and if we cannot resolve it you may terminate and take your data with you.
- Your RMM (for example SuperOps) is your vendor, not our sub-processor — we read from it on your instruction.
5. International transfers
- Production data is hosted in the European Union (Contabo, Germany). Administrative access from South Africa is limited, MFA-gated and logged.
- For EU/UK personal data, the EU 2021 Standard Contractual Clauses (Module 2 controller→processor and Module 3 processor→processor, as applicable) are incorporated into this DPA, with the UK Addendum where UK GDPR applies.
- For South African customers, this DPA provides the contractual protection POPIA section 72 requires for cross-border transfers.
6. If something goes wrong
- We notify you of a personal-data breach affecting your workspace without undue delay and within 48 hours of becoming aware, with what we know, what we are doing, and a named contact (incidents: security@angilabs.com) — so you can meet your own 72-hour clock if one applies.
- We assist with data-subject requests (access, deletion, export) and with your DPIAs, at no charge during beta.
7. When we part ways
- Export of your tenant data in machine-readable form, on request, any time.
- Full deletion of your tenant within 30 days of termination (backups purge within 90), confirmed in writing on request.
- Audit rights: security documentation and questionnaires first; an independent audit as the escalation path, at your cost, with reasonable notice.
- Liability under this DPA follows the cap in the main agreement.
Change log
- 2026-10-12 — v1.0-beta published and incorporated into the Beta Agreement.