No. You as a customer do not transmit any personal data to froach. You only provide us with a domain for the registration, for which we activate the registrations. The users agree to the data protection regulations upon registration and can exercise their data protection rights directly against froach. Therefore, froach does not provide its services as a processor, but as a responsible party.
Is the processing of personal data in the context of the use of the "froach" application a data processing agreement (DPA) pursuant to Art. 28 of the GDPR?
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