Data Processing Agreement
The terms on which Keelbits processes personal data on behalf of an organisation that installs a Keelbits app. This agreement ("DPA") supplements the Terms of Service and is incorporated into them by reference.
Last updated 2026-09-18 · Contact: privacy@keelbits.com
1. Parties and roles
This DPA is between the organisation that installs a Keelbits app on its Atlassian site (the "Customer", acting as controller) and Keelbits, operated by Yaroslav Kharchenko, private entrepreneur, registered in Ukraine (the "Provider", acting as processor). It applies to the extent the app processes personal data on the Customer's behalf.
Keelbits apps run on Atlassian Forge. The Provider writes the code that decides what the app stores and when it deletes it, but the data itself stays in Forge storage inside the Customer's Atlassian site, and the Provider has no access to it. Atlassian hosts the app and its storage as the Provider's sub-processor under the Forge Data Processing Addendum (section 6).
For data the Provider holds directly, support correspondence and licensing data from the Atlassian Marketplace, the Provider is the controller; the Privacy Policy covers that data, not this DPA.
2. Subject matter, nature and purpose
The app keeps a continuous copy of the Customer's Jira issues so that a deleted issue can be restored by a Jira administrator. Processing consists of: reading issues, comments, work logs, issue links and attachment metadata through the Jira API; storing them in the Forge storage of the Customer's installation; keeping copies of deleted issues for the retention period the Customer configures; creating a new issue when an administrator restores one; and deleting copies when retention expires, when an administrator empties the trash, or when the app is uninstalled.
3. Duration
Processing lasts for as long as the app is installed on the Customer's site. Copies of deleted issues are kept for the retention period the Customer configures (30, 90, 180 or 365 days; 90 by default) and are then removed by a daily cleanup. Uninstalling the app removes its storage (section 9).
4. Categories of data and data subjects
| Data subjects | Users of the Customer's Jira site whose accounts appear in issues: employees, contractors and customers of the Customer |
| Personal data | Atlassian account ids and display names of assignees, reporters and creators, of the authors of comments, work logs and attachments, and of the user who deleted an issue; any personal data the Customer's users have written into issue fields, comments and work logs |
| Special categories | None intended. The app stores whatever the Customer's users put into issues; the Customer decides what goes there |
5. Instructions and confidentiality
The Provider processes personal data only to provide the app's functions as described in its documentation and in this DPA. The Customer's instructions are the installation of the app, the settings its administrators choose (retention period, initial load) and the actions they take (restore, empty trash, run a personal data report). The Provider will not process the data for any other purpose. The Provider has no staff other than its operator, who keeps confidential anything a Customer shares in a support request.
6. Subprocessors
| Subprocessor | Role | Location |
|---|---|---|
| Atlassian (Atlassian Pty Ltd and its affiliates) | Hosting of the app and of its Forge SQL and key-value storage, under the Forge Data Processing Addendum | Region of the Customer's Atlassian site (Forge data residency) |
Atlassian is the only party that processes app data. The Provider uses no other subprocessor for app data and will announce a new one by email to the technical contact at least 30 days before it starts processing; the Customer may object on reasonable data protection grounds and, if no alternative is found, end the subscription. The providers of this website and of support email (Hetzner, Cloudflare) never see app data; they are listed in the Privacy Policy and on the Security page.
7. Security measures
- No external network access. The app manifest declares no egress, so data cannot leave Atlassian infrastructure (Runs on Atlassian).
- Storage inside the Customer's installation. Each installation has its own Forge storage. Atlassian applies its platform controls for encryption in transit and at rest and for tenant isolation, and publishes its certifications at atlassian.com/trust.
- Administrators only. Every operation checks the caller's Jira administrator permission on the server before the app acts.
- Least privilege. The app requests only the scopes listed on the Security page.
- No personal data in logs. Application logs record operations and error codes, not issue content or user names.
- Controlled changes. Source code and Forge deployment access belong to the operator alone; each release passes lint, type and end-to-end checks before it is deployed.
8. Data subject requests
Because the data sits in the Customer's own Atlassian site, most requests can be handled by the Customer directly: a Jira administrator can find an issue in the trash, restore or delete it, or empty the trash. When an Atlassian account is closed, the app erases that person's account id and name from all its copies within its next 7-day personal data reporting cycle; an administrator can run the report at any time from the Settings tab. For anything else the Provider assists on request at privacy@keelbits.com within 7 days.
9. Return and deletion
Uninstalling the app removes its Forge storage; there is no copy of the data anywhere else. Before uninstalling, the Customer can restore the issues it wants to keep and export them with Jira's own tools. The Provider retains no app data after termination, because it never held any.
10. Personal data breach
If the Provider becomes aware of a breach affecting the Customer's personal data, it notifies the Customer's technical contact without undue delay and no later than 72 hours after becoming aware, with what is known about the nature of the breach, the data and people affected, the likely consequences and the measures taken. The Provider also reports the incident to Atlassian through the Marketplace security incident process. The Customer remains responsible for notifying supervisory authorities and data subjects.
11. Audits
The Provider operates no infrastructure for the app, so there is nothing of its own to inspect. Audits take the form of written questions, answered within 7 days, and of Atlassian's published compliance reports. The Provider will make available the information needed to demonstrate compliance with this DPA.
12. International transfers
App data stays in the region of the Customer's Atlassian site. Any transfer inside Atlassian's infrastructure is covered by Atlassian's transfer mechanisms under the Forge Data Processing Addendum. The Provider itself transfers no app data anywhere.
13. Term, precedence and law
This DPA takes effect when the Customer installs the app and ends when processing ends under section 9. Where it conflicts with the Terms of Service, this DPA prevails for the processing of personal data. It is governed by the same law as the Terms of Service. A countersigned copy is available on request at privacy@keelbits.com.