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The addendum designates Synthesia as a data processor with respect to Customer Data, establishing the contractual basis for that processing relationship as required under applicable data protection law.
This analysis describes what Synthesia's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes the legal framework under which Synthesia processes Customer Data, positioning the business customer as the data controller and Synthesia as the data processor. This designation carries specific obligations under GDPR Article 28 for both parties.
Interpretive note: The full operative provisions of the processor designation, including scope of processing, permitted purposes, and sub-processor authorizations, are contained in the full addendum text, which was not reproduced in the content provided.
Under this clause, business customers operating as data controllers retain responsibility for the lawfulness of processing instructions given to Synthesia, while Synthesia operates under the constraints of the processor role as defined in the addendum. The specific scope of processor obligations is contained in the full addendum instrument, which was not reproduced in the content provided.
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"This addendum reflects our requirements as a processor of Customer Data.Excerpt from Synthesia's Data Processing Agreement
(1) REGULATORY LANDSCAPE: The processor designation directly engages GDPR Article 28, which requires that processing by a processor be governed by a binding contract setting out the subject matter, duration, nature, and purpose of the processing. UK GDPR contains equivalent requirements. CCPA service provider frameworks may also apply for California-based customer organizations. The ICO (Information Commissioner's Office) is the primary supervisory authority given Synthesia's UK incorporation, though EU data protection authorities retain jurisdiction over EU-established customers. (2) GOVERNANCE EXPOSURE: Medium. The designation itself is standard and required by GDPR, but the adequacy of the full addendum in meeting Article 28 requirements cannot be assessed from the content provided. Inadequate processor contracts represent a compliance gap that supervisory authorities have cited in enforcement actions. (3) JURISDICTION FLAGS: EU/EEA customers must confirm the addendum satisfies EU GDPR Article 28 requirements as interpreted by their lead supervisory authority. UK customers are subject to UK GDPR equivalents. California-based customers should assess whether the addendum functions as a CCPA service provider agreement. (4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should verify the addendum includes all Article 28 mandatory elements: processing purpose and duration, nature of processing, type of personal data and categories of data subjects, controller obligations and rights, sub-processor authorization mechanisms, and security obligations. (5) COMPLIANCE CONSIDERATIONS: Organizations should confirm execution of the DPA is recorded and that the addendum version aligns with the January 13, 2026 update date. Data mapping documentation should reflect Synthesia's processor status and the categories of personal data processed.
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This provision establishes the legal framework under which Synthesia processes Customer Data, positioning the business customer as the data controller and Synthesia as the data processor. This designation carries specific obligations under GDPR Article 28 for both parties.
Under this clause, business customers operating as data controllers retain responsibility for the lawfulness of processing instructions given to Synthesia, while Synthesia operates under the constraints of the processor role as defined in the addendum. The specific scope of processor obligations is contained in the full addendum instrument, which was not reproduced in the content provided.
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