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Data Processing Addendum

Last updated: 31 July 2026

This Data Processing Addendum ("DPA") forms part of the Terms of Service between you (the "Creator" or "Controller") and Lustra Digital LTD, trading as NoMoreManagers (the "Processor"), and applies whenever NoMoreManagers processes personal data about your fans, subscribers, or other third parties on your behalf ("Audience Data"). It does not cover your own personal data as a NoMoreManagers user — that is covered by our Privacy Policy.

1. Roles

For Audience Data (for example, a fan's username, messages, or spend, imported from a platform you connect), you are the data controller: you decide why and how that data is collected and used in your creator business, and you are responsible for having a lawful basis to have it processed. NoMoreManagers is your data processor: we process Audience Data only on your documented instructions (which include the features you use and the settings you choose in the Service), and only to provide the Service to you.

2. Subject matter, duration, and purpose

Subject matter:hosting and processing Audience Data within the Service's features (unified inbox, fan/subscriber records, revenue tracking, AI-assisted messaging suggestions, and related analytics). Duration: for as long as you maintain a NoMoreManagers account, and thereafter only as described in Section 8. Purpose: solely to provide, maintain, and improve the Service for you — never to build a profile of your fans for our own purposes, and never to sell Audience Data.

3. Categories of data subjects and data

  • Data subjects: your fans, subscribers, and other individuals who interact with your connected platforms.
  • Categories of data: usernames/handles, message content, engagement and spend history, and platform-specific identifiers made available by the platforms you connect.

4. Processor obligations

  • We process Audience Data only on your instructions, as reflected in the Service's features and your own configuration of them.
  • We impose confidentiality obligations on personnel who can access Audience Data.
  • We implement the technical and organisational security measures described in our Privacy Policy.
  • We assist you, where reasonably possible, in responding to a data subject request from one of your fans concerning their Audience Data.
  • We notify you without undue delay if we become aware of a personal data breach affecting Audience Data.

5. Sub-processors

We use the sub-processors listed in Section 11 of our Privacy Policy to provide the Service, which may include processing Audience Data (for example, database hosting via Supabase, or AI-generated message suggestions via Anthropic). By using the Service, you authorise this general use of sub-processors; we will update that list if it changes materially.

6. International transfers

Audience Data may be transferred to and processed in the United Kingdom and, via the sub-processors in Section 5, other countries including the United States. Where required, this is done under appropriate safeguards — such as the UK International Data Transfer Addendum or equivalent Standard Contractual Clauses — consistent with Section 7 of our Privacy Policy.

7. Audience Data at rest in the Service

You can access, export, and delete Audience Data associated with your account through the Service's own features and the self-service tools in Settings, without needing to raise a separate request with us.

8. Deletion or return of data

When your account is deleted, Audience Data is deleted following the same two-stage process described in Section 13 of our Privacy Policy: an initial grace period, followed by permanent erasure — subject only to any narrow legal retention obligations that apply to NoMoreManagers itself (for example, security logs kept for a limited period after account closure).

9. Audits

On reasonable written request, we will provide you with information reasonably necessary to demonstrate compliance with this DPA. We do not currently offer on-site audits given the scale of the Service; if you have a specific compliance requirement that needs one, contact us to discuss it.

10. Contact

Questions about this DPA can be sent to hello@nomoremanagers.com.

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