PewbookPewbook

Data processing agreement

Last updated 2 October 2026

This agreement is between the parish or organisation using Pewbook (the "customer", and the controller) and Lewis Cummins, trading as Pewbook (the processor). It forms part of our terms of service, and the customer accepts it by accepting those terms. It covers what UK GDPR Article 28(3) requires.

1. What, why and for how long

Pewbook processes personal data to run Pewbook for the customer: its public page, service times, staff logins and the modules it uses, such as Mass intentions. This agreement lasts as long as the customer's account.

2. Types of data and people

3. Only on the customer's instructions

Pewbook processes the data only on the customer's documented instructions. Using Pewbook, and choosing its settings, is the instruction. If the law ever requires us to do something else, we'll tell the customer first unless the law forbids it.

4. Confidentiality

Anyone at Pewbook who can access the data is bound to keep it confidential.

5. Security

6. Sub-processors

The customer gives general written permission for Pewbook to use these sub-processors:

NameWhat forWhere data is held
SupabaseThe database, where each parish's records are kept.EU/UK region
Fly.ioRuns the Pewbook server.London, UK
CloudflareHosts the website and serves its pages.Global network
ResendSends emails: request checks, confirmations and staff login links.United States, under UK transfer safeguards
StripeBilling for paid modules. Parish billing details only, never parishioners' data.UK/EU and United States, under UK transfer safeguards
Grafana Cloud (from when we add monitoring)Server logs and performance measurements.EU region

We'll email the customer at least 30 days before adding or replacing a sub-processor. The customer can object. If we can't agree a way forward, the customer can end this agreement and the terms. Each sub-processor is bound by data protection terms at least as strong as these.

7. Helping the customer

Pewbook will help the customer answer requests from people using their data protection rights, such as access or deletion, and pass on any such request sent to us. We'll also help the customer meet its own obligations, such as data protection impact assessments and dealing with the Information Commissioner's Office.

8. Data breaches

If Pewbook becomes aware of a personal data breach affecting the customer's data, we'll tell the customer without undue delay, and within 48 hours, with what we know and what we're doing about it.

9. At the end

When the account ends, the customer chooses whether we return its data (as an export) or delete it, as described in the terms. Records the parish must keep, such as the Mass intentions register, are handed over before anything is deleted.

10. Showing we comply

Pewbook will give the customer the information it needs to show that this agreement is being kept. The customer can ask for an audit, with reasonable notice.

11. Transfers outside the UK and EU

We don't transfer the data outside the UK or EU, except where a sub-processor does so under UK adequacy regulations or the UK International Data Transfer Addendum.

Contact

Lewis Cummins, trading as Pewbook
33 Appleyard Close, Cheltenham, GL51 9FF
[email protected]