Data Processing Agreement
Last updated: September 3, 2026
Introduction
This Data Processing Agreement (“DPA”) forms part of the Terms of Service between you (“Data Subject” or “User”) and 3D Reality Labs LLC (“Data Controller” or “Company”) regarding the processing of personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.
This DPA applies to all personal data processing activities carried out by Propelr in connection with the provision of our LinkedIn and X content management services.
Definitions
Personal Data
Any information relating to an identified or identifiable natural person, including but not limited to names, email addresses, LinkedIn and X profile data, content, and usage analytics.
Processing
Any operation performed on personal data, including collection, storage, analysis, sharing, and deletion.
Data Controller
3D Reality Labs LLC, which determines the purposes and means of processing personal data.
Data Subject
The individual whose personal data is being processed, i.e., our users.
Legal Basis for Processing
We process your personal data based on the following legal grounds under GDPR:
Contract Performance (Article 6(1)(b))
Processing necessary for the performance of our service contract with you, including content creation, scheduling, and analytics.
Legitimate Interest (Article 6(1)(f))
Processing for our legitimate business interests, such as service improvement, analytics, and fraud prevention, balanced against your privacy rights.
Consent (Article 6(1)(a))
Processing based on your explicit consent for marketing communications and optional analytics features.
Legal Obligation (Article 6(1)(c))
Processing required to comply with legal obligations, such as data retention requirements and regulatory reporting.
Categories of Personal Data
Identity Data
- Name and email address
- LinkedIn profile information
- Company and professional role
- Profile preferences and settings
Content Data
- Posts and content created
- Drafts and scheduled content
- AI-generated content suggestions
- Content performance analytics
Usage Data
- Platform interaction patterns
- Feature usage statistics
- Session duration and frequency
- Error logs and debugging data
Technical Data
- IP addresses and device information
- Browser type and version
- Operating system details
- Cookies and tracking data
Processing Purposes
Service Provision
- Content creation and management
- LinkedIn integration and posting
- Analytics and performance tracking
- User authentication and security
Service Improvement
- AI model training and optimization
- Feature development and enhancement
- User experience improvements
- Performance monitoring and debugging
Communication
- Service-related notifications
- Support and customer service
- Marketing communications (with consent)
- Legal and regulatory updates
Legal Compliance
- Regulatory compliance and reporting
- Fraud prevention and security
- Dispute resolution and enforcement
- Data retention requirements
Data Security Measures
We implement appropriate technical and organizational measures to ensure the security of your personal data:
Technical Safeguards
- End-to-end encryption for data transmission
- Encryption at rest for stored data
- Secure authentication and access controls
- Regular security audits and penetration testing
- Automated backup and disaster recovery
- Network security and intrusion detection
Organizational Safeguards
- Employee training on data protection
- Access controls and role-based permissions
- Confidentiality agreements and policies
- Incident response and breach procedures
- Regular compliance assessments
- Vendor and third-party risk management
International Data Transfers
Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). We ensure appropriate safeguards are in place:
Adequacy Decisions
Transfers to countries with adequate data protection as determined by the European Commission.
Standard Contractual Clauses (SCCs)
EU-approved contractual clauses ensuring adequate protection for personal data transferred to third countries.
Certification Schemes
Industry-standard certifications and codes of conduct ensuring compliance with data protection requirements.
Your Data Subject Rights
Under GDPR, you have the following rights regarding your personal data:
Right of Access (Article 15)
Request confirmation of whether we process your data and obtain a copy of the personal data we hold about you.
Right to Rectification (Article 16)
Request correction of inaccurate or incomplete personal data.
Right to Erasure (Article 17)
Request deletion of your personal data in certain circumstances.
Right to Portability (Article 20)
Receive your data in a structured, machine-readable format and transfer it to another controller.
Right to Object (Article 21)
Object to processing of your personal data for certain purposes, including direct marketing.
To exercise your rights: Contact us at 3drealitylabs@gmail.com or use the data management tools in your account settings. We will respond to your request within 30 days.
Data Retention
We retain personal data only as long as necessary for the purposes outlined in this DPA or as required by law:
Data Breach Notification
In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will:
- Notify the relevant supervisory authority within 72 hours of becoming aware of the breach
- Inform affected data subjects without undue delay if the breach poses a high risk
- Provide clear information about the nature of the breach and measures taken
- Offer guidance on steps you can take to protect yourself
- Maintain detailed records of all breaches for regulatory compliance
Contact Information
For questions about this Data Processing Agreement or to exercise your data protection rights, please contact us:
Data Protection Officer: 3drealitylabs@gmail.com
Privacy Inquiries: 3drealitylabs@gmail.com
General Support: 3drealitylabs@gmail.com
Legal Department: 3drealitylabs@gmail.com