Effective Date: 02/25/2026
Service: Cult Translator
Provider: Cult Extensions
Contact: contact@cultextensions.com
1. Purpose
This Data Processing Addendum (“DPA”) forms part of the Terms of Service governing the use of Cult Connector and Cult Translator.
This DPA describes how personal data is processed when customers use Cult Connector or Cult Translator and applies automatically to customers who submit personal data for processing through the Service.
This DPA is designed to align with:
- Brazilian General Data Protection Law (LGPD – Lei nº 13.709/2018)
- EU General Data Protection Regulation (GDPR) principles
- Other applicable data protection laws
2. Roles of the Parties
For purposes of applicable data protection law:
- The Customer acts as Data Controller.
- Cult Extensions acts as Data Processor.
The Customer determines the purpose and means of processing any personal data submitted through the Service.
Cult Extensions processes such data solely to provide and support the Service.
3. Scope of Processing
3.1 Categories of Data
Depending on usage, processing may include:
- Text submitted for translation or localization
- Account email address
- License and subscription metadata
- Operational usage metrics
- Hashed device identifiers
- Limited infrastructure metadata (e.g., IP address for abuse prevention)
3.2 Nature of Processing
Processing activities may include:
- Transmission of text to translation APIs
- License validation and subscription enforcement
- Infrastructure hosting and service delivery
- Security monitoring and fraud prevention
Translation content is processed transiently and is not stored in Cult Extensions’ application database.
4. Purpose of Processing
Personal data is processed solely for:
- Providing the requested translation or localization service
- Enforcing licensing terms
- Maintaining service security and integrity
- Supporting customer operations
Cult Extensions does not independently determine new purposes for customer content.
5. Translation Content Handling
When translation features are used:
- Content is transmitted securely via HTTPS.
- Translation processing occurs through external API providers.
- Translation content is not retained in Cult Extensions’ systems after processing.
- Translation content is not used for advertising, resale, profiling, or model training by Cult Extensions.
Customers remain responsible for ensuring they have a lawful basis to process submitted content.
6. Subprocessors
Cult Extensions engages trusted third-party subprocessors to operate the Service. These may include:
- Cloud infrastructure providers (hosting)
- Payment processing providers
- Translation API providers
- Website analytics providers
Each subprocessor operates under its own security and compliance standards.
Upon reasonable request, Cult Extensions may provide updated information regarding subprocessors.
7. International Transfers
Because the Service operates globally, personal data may be processed in jurisdictions outside the Customer’s country of residence.
Cult Extensions implements appropriate safeguards consistent with applicable data protection laws when engaging subprocessors that operate internationally.
8. Security Measures
Cult Extensions implements technical and organizational measures proportionate to the nature and scale of the Service, including:
- TLS encryption in transit
- Restricted access to production infrastructure
- Hashed device identifiers
- Separation of billing and operational systems
- Logical access controls
- No storage of translation content
While no system can guarantee absolute security, we maintain practices appropriate for a cloud-based software service.
9. Confidentiality
Personnel with access to personal data are subject to confidentiality obligations.
Customer content processed through the Service is not disclosed except as necessary to provide the Service or comply with legal obligations.
10. Data Subject Rights Assistance
Upon reasonable request, Cult Extensions will assist the Customer in responding to data subject rights requests to the extent such requests relate to data processed by Cult Extensions on behalf of the Customer.
Requests may be directed to:
11. Data Retention and Deletion
Translation content is not stored after processing.
Operational metadata and subscription data are retained only for:
- Service continuity
- Fraud prevention
- Legal and accounting requirements
Upon termination of service, personal data will be retained only as required by law or for legitimate operational purposes.
12. Incident Notification
In the event of a confirmed data security incident affecting personal data processed under this DPA, Cult Extensions will:
- Notify affected customers without undue delay
- Provide available relevant information
- Cooperate in mitigation efforts
13. Liability
Liability under this DPA is subject to the limitations set forth in the Terms of Service.
Nothing in this DPA restricts mandatory rights under applicable data protection law.
14. Governing Framework
This DPA operates in conjunction with the Terms of Service and shall be interpreted consistently with applicable data protection laws.
15. Contact
For data protection inquiries:
Cult Extensions
Registered in Brazil
contact@cultextensions.com