Data Processing Agreement
Last updated September 14, 2026View Privacy Policy →View Terms of Service →
1.Status of this page
This page is APT’s in-app Data Processing Agreement home. It is not executed and is not a signed contract. For this pilot, lines marked [COUNSEL] are placeholders, not legal advice, and not a final counsel-approved body.
2.What a Data Processing Agreement is
A Data Processing Agreement describes how a processor handles personal data on behalf of a controller. Opening this page does not create that contract and is not a compliance certification.
3.Roles in this product
For payment data APT hosts on your behalf, APT acts as a processor and you (the merchant or partner) remain the controller for your payers.
Party erasure and staff retention tools are not this agreement. Those tools do not replace a contract from counsel.
4.What this page is not
- Not an e-sign or countersign flow.
- Not a claim that your program is certified under any privacy law.
- Not a Party wipe, ledger wipe, or merchant forget-me control.
- Not a place to enter a card number.
5.Processing instructions
[COUNSEL] Pilot placeholder — not legal advice. Processing instructions for an executed agreement are not stated here. This heading is an authoring slot. Viewing this page does not authorize processing as if a contract were in force.
6.Sub-processors
[COUNSEL] Pilot placeholder — not legal advice. APT does not publish a live sub-processor list on this page. Do not treat this heading as an executed disclosure.
7.International transfers
[COUNSEL] Pilot placeholder — not legal advice. Transfer mechanisms are not listed here as executed warranties.
8.Security
[COUNSEL] Pilot placeholder — not legal advice. Security measures that would belong in an executed agreement are not listed here as if they were signed.
9.Audit
[COUNSEL] Pilot placeholder — not legal advice. Audit rights are not granted by opening this page.