> For the complete documentation index, see [llms.txt](https://docs.autopilotmonitor.com/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.autopilotmonitor.com/legal/data-privacy-agreement-dpa.md). # Data Processing Agreement (DPA) The data processing agreement for Autopilot Monitor under Art. 28 GDPR, based on the EU Commission's standard contractual clauses (Implementing Decision (EU) 2021/915) ## Scope and conclusion of this agreement This Data Processing Agreement ("DPA") governs the processing of personal data by glueckkanja AG on behalf of the customer in connection with **Autopilot Monitor**. It applies to Autopilot Monitor Community Edition, Autopilot Monitor Pro, and Pro trials. ### Parties * **Controller**: the customer, being the organization that activates an Autopilot Monitor tenant. The controller is identified by the Microsoft Entra tenant ID and the organization details provided during tenant activation (see Annex I). * **Processor**: glueckkanja AG, Kaiserstraße 39, 63069 Offenbach am Main, Germany ("we", "us", "our"). ### How this agreement is concluded This DPA is concluded electronically. By ticking the acceptance checkbox during tenant activation in the Autopilot Monitor portal, the person acting for the customer confirms that they are authorized to bind the customer, and the customer agrees to this DPA including its Annexes. The DPA is concluded at the moment of acceptance; that moment is the accession date within the meaning of Annex I. We record the Entra tenant ID, the user principal name of the accepting administrator, the timestamp, and the version of this DPA that was accepted. Where the customer has concluded an individually signed data processing agreement with us that covers Autopilot Monitor, that agreement prevails over this page. ### Delegated tenants Where a customer on the Pro plan manages other tenants (delegated tenants), each delegated tenant is a controller in its own right for the data of its devices and users. The administrator of the delegated tenant accepts this DPA when granting admin consent for the delegation in the portal; a delegation, including one assigned centrally by us at the customer's request, becomes active only after that acceptance. The managing customer and its users act as recipients authorised by the delegated tenant through that consent. ### Existing tenants Tenants activated before this DPA was published are asked to accept it at the next sign-in of a tenant administrator. Until then, this DPA applies from its effective date; a customer that does not agree can end the processing by offboarding its tenant. ### Basis and structure Clauses 1 to 10 of this DPA are the standard contractual clauses between controllers and processors adopted by the European Commission under Article 28(7) GDPR (Commission Implementing Decision (EU) 2021/915). They are reproduced unchanged; the optional docking clause (Clause 5) is not used. The Annexes are completed for Autopilot Monitor: * **Annex I** – List of parties (below) * **Annex II** – Description of the processing (below) * **Annex III** – Technical and organisational measures (subpage) * **Annex IV** – List of sub-processors (subpage) This DPA is governed by German law. The place of jurisdiction is the one stated in the agreement under which you use Autopilot Monitor. {% hint style="info" %} For a technical description of how Autopilot Monitor handles data, see the Security & Privacy FAQ and Data Flows & External Services. Those pages explain the architecture; this page is the binding agreement. {% endhint %} ### How to accept Customers accept the DPA during tenant activation. Administrators of delegated tenants accept it when granting admin consent for the delegation. ## Section I ### Clause 1 – Purpose and scope 1. The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). 2. The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725. 3. These Clauses apply to the processing of personal data as specified in Annex II. 4. Annexes I to IV are an integral part of the Clauses. 5. These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. 6. These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. ### Clause 2 – Invariability of the Clauses 1. The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them. 2. This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects. ### Clause 3 – Interpretation 1. Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation. 2. These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively. 3. These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects. ### Clause 4 – Hierarchy In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail. ### Clause 5 – Docking clause (optional) Not used. ## Section II – Obligations of the Parties ### Clause 6 – Description of processing(s) The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II. ### Clause 7 – Obligations of the Parties #### 7.1 Instructions 1. The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented. 2. The processor shall immediately inform the controller if, in the processor's opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions. #### 7.2 Purpose limitation The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller. #### 7.3 Duration of the processing of personal data Processing by the processor shall only take place for the duration specified in Annex II. #### 7.4 Security of processing 1. The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects. 2. The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality. #### 7.5 Sensitive data If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person's sex life or sexual orientation, or data relating to criminal convictions and offences ("sensitive data"), the processor shall apply specific restrictions and/or additional safeguards. #### 7.6 Documentation and compliance 1. The Parties shall be able to demonstrate compliance with these Clauses. 2. The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses. 3. The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller's request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor. 4. The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice. 5. The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request. #### 7.7 Use of sub-processors 1. The processor has the controller's general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 30 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object. 2. Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. 3. At the controller's request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy. 4. The processor shall remain fully responsible to the controller for the performance of the sub-processor's obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations. 5. The processor shall agree a third party beneficiary clause with the sub-processor whereby, in the event the processor has factually disappeared, ceased to exist in law or has become insolvent, the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data. #### 7.8 International transfers 1. Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725. 2. The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7 for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met. ### Clause 8 – Assistance to the controller 1. The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller. 2. The processor shall assist the controller in fulfilling its obligations to respond to data subjects' requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (1) and (2), the processor shall comply with the controller's instructions. 3. In addition to the processor's obligation to assist the controller pursuant to Clause 8(2), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor: 1. the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a "data protection impact assessment") where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons; 2. the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk; 3. the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated; 4. the obligations in Article 32 of Regulation (EU) 2016/679. 4. The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required. ### Clause 9 – Notification of personal data breach In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor. #### 9.1 Data breach concerning data processed by the controller In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller: 1. in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant (unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons); 2. in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller's notification, and must at least include: 1. the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned; 2. the likely consequences of the personal data breach; 3. the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects. Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay; 3. in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons. #### 9.2 Data breach concerning data processed by the processor In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least: 1. a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned); 2. the details of a contact point where more information concerning the personal data breach can be obtained; 3. its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects. Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay. The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller's obligations under Articles 33 and 34 of Regulation (EU) 2016/679. ## Section III – Final provisions ### Clause 10 – Non-compliance with the Clauses and termination 1. Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason. 2. The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if: 1. the processing of personal data by the processor has been suspended by the controller pursuant to paragraph (1) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension; 2. the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725; 3. the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. 3. The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1(2), the controller insists on compliance with the instructions. 4. Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses. ## Annex I – List of parties ### Controller The customer. Identity and contact details of the controller are those provided during tenant activation in the Autopilot Monitor portal: | Item | Value | | ----------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | | Name and address | The organization named during tenant activation, identified by its Microsoft Entra tenant ID | | Contact person | The administrator who accepted this DPA during tenant activation (name and e-mail address as provided), or any administrator of the tenant named subsequently | | Data protection officer | To be communicated by the controller, if appointed, via the [contact-form](https://products.glueckkanja.com/support/tickets/new?ticket_form=drop_a_question_\(autopilotmonitor\)) | | Accession | By acceptance of this DPA during tenant activation, or, for a delegated tenant, when granting admin consent for the delegation; the accession date is the recorded timestamp of acceptance | The controller shall keep its contact details current. Notices under this DPA to the controller are sent to the e-mail address of the accepting administrator unless the controller has named another contact. ### Processor | Item | Value | | ----------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------- | | Name | glueckkanja AG | | Address | Kaiserstraße 39, 63069 Offenbach am Main, Germany | | Contact | Autopilot Monitor team, via the [contact-form](https://products.glueckkanja.com/support/tickets/new?ticket_form=drop_a_question_\(autopilotmonitor\)) | | Data protection officer | Jasmin Muhmenthaler-Sturm, Datenbeschützerin GmbH, Unterer Sand 9, 94209 Regen, Germany, +49 9921 88229002, | | Accession | By publication of this DPA and provision of the acceptance mechanism during tenant activation | ## Annex II – Description of the processing ### Categories of data subjects whose personal data are processed * Employees and other persons of the controller who use devices that are enrolled through Windows Autopilot, Autopilot Device Preparation, or Windows 365 and monitored by Autopilot Monitor (device users). * Employees and other persons of the controller who use the Autopilot Monitor portal or the MCP integration (administrators, operators, viewers, members). * Where the controller is a delegated tenant: its device users and portal users, whose data is additionally accessible to the users of the managing tenant. * Employees of the controller who contact our support or submit feedback or support reports. ### Categories of personal data processed * **Device identity data**: serial number, device name, manufacturer, model, hardware identifiers, and the Microsoft Entra tenant ID the device enrolls into. * **Enrollment telemetry**: enrollment phases, Enrollment Status Page stages, application and script installation results, policy and CSP activity, reboots, timings and failure codes, OS build, hardware, disk and network state. * **Data collected through gather rules** configured by the controller (registry values, files, event log entries, WMI data, output of allow-listed diagnostic commands), within the guardrails compiled into the agent. * **User names** read from the Windows interactive session to detect sign-in state and evaluate exclusion rules (processed transiently, not stored as a session attribute); a configured automatic logon user name may appear as a diagnostic finding. * **Location and network data**, if geolocation is enabled by the controller: country, region, city, approximate coordinates, and the device's outbound public IP address (stored as a diagnostic event). * **Diagnostics packages**, if the controller enables hosted diagnostics upload or includes a package in a support report: agent logs and state, Intune Management Extension logs, session information, RealmJoin logs where enabled, and additional log paths configured by the controller. These may contain user names and other personal data contained in the logs. * **Portal and MCP user data**: user principal name, assigned role, sign-in activity, and actions recorded in the tenant audit log. * **Notification and integration data**: session, device and finding details sent to notification destinations configured by the controller, and data retrieved by AI assistants the controller's users connect through MCP. * **Support and feedback data** submitted by the controller's administrators through the portal or the ticket system: free-text comments, session exports and reports, attached logs, screenshots and diagnostics packages. Such attachments may contain any of the categories listed above. Processing for which glueckkanja AG is itself the controller is not covered by these Clauses; see the [Privacy Policy](https://www.autopilotmonitor.com/privacy). This concerns in particular the operation and security of the service, account administration and operational telemetry, the verification of licence-compliant use (see below), and the contact and correspondence data of the controller's employees processed for managing the customer relationship (sales, contract administration, support communication). ### Sensitive data processed (if applicable) and applied restrictions or safeguards Not applicable. Autopilot Monitor is not intended for the processing of sensitive data, and the controller shall not configure gather rules or additional log paths that collect such data. The agent enforces hard blocks (e.g. user profile directories, security registry hives, security event logs) that cannot be lifted by any setting. ### Nature of the processing Collection (receipt of telemetry from the agent), storage, automated analysis (evaluation of analyze rules), display to the controller's users, transmission to destinations configured by the controller, access by our personnel under the platform roles described in the Security & Privacy FAQ, and deletion. ### Purpose(s) for which the personal data is processed on behalf of the controller 1. **Monitoring, diagnosis and analysis** of the enrollment of the controller's devices, including fleet health, geographic and SLA reporting, software inventory and vulnerability correlation, notifications, and natural-language queries by the controller's users via MCP. 2. **Support**: handling of support requests, incidents and feedback of the controller, including the analysis of the controller's sessions and of data the controller submits to us through the portal or the ticket system. 3. **Operation of the service**: capacity, performance and health analysis of the platform, carried out on aggregated or pseudonymised data wherever possible. 4. **Improvement of detection**: analysis of individual enrollment sessions by our personnel to develop and refine analyze rules, IME log patterns and the decision engine, from which all tenants benefit. The controller instructs us to carry out this analysis and may withdraw this instruction at any time via the [support form](https://products.glueckkanja.com/support/tickets/new?ticket_form=drop_a_question_\(autopilotmonitor\)), in which case the controller's sessions are excluded from it. **Verification of licence-compliant use.** In addition to the purposes above, we regularly verify that the service is used in accordance with the Licensing Policy and the agreement under which the controller uses Autopilot Monitor, in particular the plan entitlements, the number of delegated tenants, the restrictions on use, and the limits and quotas. This verification is carried out in our own responsibility on the basis of that agreement, not on behalf of the controller. It uses tenant configuration and usage data (Entra tenant ID, plan, session volumes, number of delegated tenants, portal and MCP user accounts and their roles, rate-limit and quota counters), not the content of enrollment sessions or diagnostics. ### Duration of the processing The processing takes place for the duration of the controller's use of Autopilot Monitor. * Enrollment sessions and their events, findings and hosted diagnostics are retained according to the retention period configured by the controller (default 90 days; 7 to 90 days on Community Edition, 7 to 365 days on Pro) and purged automatically thereafter. * Operational records have fixed lifetimes as described in the Security & Privacy FAQ. * The controller can delete individual sessions at any time and can end the processing by offboarding its tenant, which removes all tenant-scoped data. Offboarding is the deletion within the meaning of Clause 10(4). Autopilot Monitor is a monitoring system, not a system of record: a general return of data is not offered. Before offboarding, the controller can export session data and reports through the export functions of the portal. * Support tickets, including data of the controller contained in them, are retained by glueckkanja AG for the duration of the business relationship and thereafter for as long as required by statutory retention obligations and for evidencing the services rendered, generally 5 years after the end of the year in which the ticket was closed. * Custom rules and IME log patterns authored by the controller, and product feedback submitted by the controller, contain no personal data and are archived rather than deleted on offboarding; they are removed on request. ## Annex III – Technical and organisational measures See the subpage [Technical and organisational measures](/legal/data-privacy-agreement-dpa/technical-and-organisational-measures-toms.md). ## Annex IV – List of sub-processors See the subpage [List of sub-processors](/legal/data-privacy-agreement-dpa/list-of-sub-processors.md). ## Version and changes * **Version:** 2026-09-1.7 * **Effective:** 2026-09-10 Clauses 1 to 10 are standard contractual clauses and are not modified. We may update the Annexes, for example when the processing changes or when sub-processors are added or replaced. Changes are announced under Service Announcements at least 30 days before they take effect. The announcement of a change to the list of sub-processors is the notification under Clause 7.7(1); the controller may object within that period via the [support form](https://products.glueckkanja.com/support/tickets/new?ticket_form=drop_a_question_\(autopilotmonitor\)). Where an objection cannot be resolved, the controller may end the processing by offboarding its tenant. Previous versions of this DPA are available on request. --- # Agent Instructions This documentation is published with GitBook. GitBook is the documentation platform designed so that both humans and AI agents can read, navigate, and reason over technical content effectively. 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