Sigil by Tophhie Cloud

Data Processing Agreement

Last updated: 24 September 2026 · version 2026-09-24

These terms govern our processing of personal data on your organisation's behalf. They form part of the Terms of Use and take effect when an administrator accepts them in the Sigil portal, or when we agree them with you in writing.

This is an agreement between your organisation and Tophhie Cloud Ltd, a company registered in England and Wales under number 17393069, whose registered office is at 21 Manor Way, Hoyland, Barnsley, England, S74 9QX ("we", "us").

1. Roles and scope

Your organisation is the controller of the personal data Sigil processes from your Microsoft 365 directory. Tophhie Cloud Ltd is the processor, acting only on your instructions. Where an MSP partner manages Sigil for you, that partner acts as your processor and we act as a sub-processor to them; the protections below still apply to your data.

In this agreement "data protection law" means the UK GDPR and Data Protection Act 2018, and the EU GDPR where it applies to your processing.

2. Subject matter, duration, nature and purpose

Subject matterRendering, managing and reporting on email signatures for your organisation.
DurationFor as long as your organisation remains connected to the service, plus the deletion period in section 9. Cancelling a subscription does not by itself end the processing: your data is retained so that re-joining restores it (section 9).
NatureReading directory attributes, storing templates and images, rendering signature HTML, and recording metadata-only activity telemetry.
PurposeTo provide the Sigil service to you, and nothing else. We do not use your data to train models, to build profiles, or for advertising.

Categories of data subject

Types of personal data

What is out of scope

Sigil does not process the content of your users' email, the identities of their recipients, or rendered signature HTML in telemetry. It reads your directory and never writes to it. No special category data under Article 9 is requested by the service; if you place such data in a template or an extension attribute, you do so as controller and remain responsible for the lawfulness of doing so.

3. Our obligations as processor

4. Security

We implement appropriate technical and organisational measures under Article 32, including:

5. Sub-processors

You give general authorisation for the sub-processors below. We remain liable for their performance and impose data protection obligations on them no less protective than these.

Sub-processorPurposeLocation
MicrosoftIdentity (Entra ID) and directory data (Microsoft Graph)Your own tenant's region
CloudflareApplication hosting, storage and cachingStored data in the EU; cached copies on its global network
StripeSubscription billing and payment card processingUK/EU and US

We will give you at least 30 days' notice before adding or replacing a sub-processor. If you reasonably object on data protection grounds within that period, you may terminate the affected part of the service without penalty and receive a pro-rata refund of prepaid fees.

6. International transfers

Your directory data and content are stored in the United Kingdom or European Economic Area. To serve signatures quickly wherever your users are, Cloudflare also holds cached copies of rendered signatures, and of the directory details they are built from, on its global network. Those copies expire on their own and can sit outside the UK and EEA. That caching, and any transfer of personal data outside the UK or EEA by a sub-processor, is covered by an adequacy decision or by the UK Addendum to the EU Standard Contractual Clauses, which are incorporated into this agreement by reference where required.

7. Assisting you

8. Personal data breaches

We will notify you without undue delay, and in any event within 48 hours of becoming aware of a personal data breach affecting your data. The notification will describe the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, and the measures taken or proposed. Where we cannot provide all of that at once, we will provide it in phases without further undue delay.

9. Return and deletion

You may export your templates, images and activity data at any time from the portal. Cancelling your subscription does not initiate deletion: your organisation's data (templates, images, cached signatures, activity telemetry and the tenant record) is retained so that, should you re-join, your signatures are restored exactly as you left them rather than rebuilt from scratch. Deletion is initiated on your request — from the portal, by asking an administrator in the platform console, or in writing to privacy@usesigil.app — and we will then delete that data within 30 days, except where law requires us to retain it. Backups are overwritten on their normal cycle, within 90 days, and remain protected by this agreement until then.

10. Audit

We will make available the information reasonably necessary to demonstrate compliance with Article 28, and will respond to a reasonable security questionnaire once in any twelve-month period. Where that is insufficient to satisfy a supervisory authority, you may audit us on 30 days' notice, no more than once a year unless a breach or a regulator requires otherwise, during business hours, subject to confidentiality, and without access to other customers' data.

11. Liability and precedence

Liability under this agreement is subject to the limits in the Terms of Use. Where this agreement conflicts with the Terms of Use on the processing of personal data, this agreement prevails. Where it conflicts with a separate signed data processing agreement between us, that signed agreement prevails.

12. Changes

We may update these terms. When the substance changes we will publish a new version and ask your administrator to accept it in the portal, so that the version you accepted is always on record. Changes that materially reduce your protections will be notified at least 30 days ahead.

Contact

Data protection enquiries: privacy@usesigil.app.