Legal

Data Processing

Last updated: February 26, 2026

Legal Entity: New Horizon Code PTY LTD (ABN: 61 634 659 804) trading as Vexion

Jurisdiction: Queensland, Australia

1. Purpose and Scope

This Data Processing Agreement ("Agreement" or "DPA") governs the processing of Personal Information by Vexion on behalf of customers in connection with the provision of Services.

This DPA forms part of the contractual agreement between you ("Customer", "Controller", "you", or "your") and Vexion ("Processor", "we", "us", or "our").

This Agreement applies where Vexion processes Personal Information on behalf of customers.

2. Definitions

  • "Personal Information" means information relating to an identified or identifiable individual.
  • "Processing" means collection, storage, access, transmission, or other handling of Personal Information.
  • "Controller" means the entity determining the purpose and means of Processing.
  • "Processor" means the entity Processing Personal Information on behalf of the Controller.
  • "Services" means infrastructure, hosting, and related services provided by Vexion.

3. Roles and Responsibilities

Customers act as Controllers of Personal Information.

Vexion acts as a Processor of Personal Information only to the extent necessary to provide Services.

Customers are responsible for ensuring lawful Processing of Personal Information.

4. Scope of Processing

Vexion may process Personal Information solely for the purpose of providing Services.

Processing may include:

  • Storage;
  • Transmission;
  • Backup;
  • Infrastructure operations;
  • Security monitoring.

Vexion does not determine the purpose of Processing.

5. Customer Obligations

Customers are responsible for:

  • Compliance with applicable privacy laws;
  • Obtaining necessary consents;
  • Lawful collection of Personal Information;
  • Ensuring lawful use of Services.

6. Security Measures

Vexion implements reasonable technical and organizational safeguards designed to protect Personal Information.

Security measures may include:

  • Access controls;
  • Encryption where applicable;
  • Monitoring systems;
  • Infrastructure protections.

No system can guarantee complete security.

7. Confidentiality

Vexion personnel are subject to confidentiality obligations.

8. Subprocessors

Vexion may engage third-party subprocessors to provide Services.

Subprocessors may include infrastructure providers and payment processors.

Vexion will take reasonable steps to ensure subprocessors implement appropriate safeguards.

9. International Transfers

Personal Information may be transferred to jurisdictions outside Australia.

Customers consent to such transfers where necessary to provide Services.

10. Data Breach Notification

Where required by law, Vexion will notify customers of confirmed data breaches affecting Personal Information under its control.

11. Assistance to Customers

Vexion will provide reasonable assistance to customers in fulfilling legal obligations, where technically feasible.

12. Data Retention and Deletion

Upon termination of Services, Vexion may delete Personal Information without liability.

Customers are responsible for exporting data prior to termination.

13. Customer Responsibility for Content

Customers retain full responsibility for Personal Information contained within Customer Content.

Vexion does not control Customer Content.

14. Limitation of Liability

To the maximum extent permitted by law, Vexion is not liable for Processing conducted on behalf of customers.

Customers assume responsibility for lawful Processing.

15. Compliance with Laws

Both parties agree to comply with applicable privacy laws.

16. Amendments

Vexion may modify this DPA at any time.

Changes become effective upon publication.

Continued use of Services constitutes acceptance.

17. Survival

This Agreement survives termination of Services.

18. Governing Law

This Agreement is governed by the laws of Queensland, Australia.

You submit to the exclusive jurisdiction of Queensland courts.

19. Contact Information

New Horizon Code PTY LTD (ABN: 61 634 659 804) trading as Vexion

Suite 121 Level 14, 167 Eagle St
Brisbane QLD 4000
Australia

Privacy: privacy@vexion.io

Legal: legal@vexion.io