Roles and scope
This is a negotiation framework, not an executed agreement. The tutor or organization determining purposes and means for learner information is controller; Wolf Softworks S.R.L. may act as processor for contracted functions under documented instructions. Its own account and security processing must be distinguished.
The proposed scope covers hosting, organization, display, export and deletion for learners, parents, tutors and members: identity and contact, scheduling, attendance, manual financial records and files. Duration follows the contract and agreed return/deletion rules. This framework does not authorize uploading special categories of information.
Required agreement obligations
Process only on documented instructions, including transfers; ensure authorized-person confidentiality and Article 32 technical and organizational measures; assist with rights, incidents, impact assessments and consultation; notify the controller without undue delay after becoming aware of a breach; flag instructions considered unlawful.
Subprocessors need prior specific or general authorization, change notification and an objection opportunity under the agreement. Relevant obligations must flow down contractually. The controller must receive information demonstrating compliance and support for audits under Article 28.
At termination, the controller chooses return or deletion of data and copies, except retention required by law. Concrete deadlines, backups and restore reconciliation must be agreed and verified; unverified provider deletion is not promised.
Annexes needed before execution
Party identities and signatories; instructions, purposes, duration, people and data categories; provider and country inventory; transfer mechanisms; actual security, access and restore measures; incident and rights contacts and workflow; return, deletion, audit and subprocessor authorization.
This framework does not replace a signed or otherwise validly accepted agreement and does not establish unapproved liability terms, incident deadlines or transfers.