Data Processing Agreement

Last updated: October 29, 2026

This page is for organisations that use Panoramr to make tours that contain personal data, such as schools, colleges, nurseries, care providers and businesses, and for their data protection officers. It sets out the agreement under which we process that personal data for you, as Article 28 of the UK GDPR requires, with the details that article asks for.

In short. Our agreement with you as your processor is clause 6 of our Terms. It is part of the contract you accept when you create an account or buy from us, so there is nothing more to sign. This page sets that clause out with the details of the processing, our security measures and our sub-processors. If this page and clause 6 ever disagree, clause 6 applies.

1. The parties and their roles

The processor is Admin Accelerator Ltd trading as Panoramr, company number 14237476 (registered in England and Wales), whose registered office is at Boho One, Bridge Street West, Middlesbrough, TS2 1AE ("Panoramr", "we", "us"). The controller is the organisation that has the account, or for which the account is used ("you").

You decide what your tours show and who can see them, so you are the controller of the personal data in them: the people, homes and belongings in your photos, the details of the people you invite to work on your tours, and the counts of visits to your tours. We are the controller only of the data we need to run Panoramr for you: your account, your payments, what you send us, the reports people make, and our own records and logs. Our Privacy Policy covers those.

2. What we agree to

Under clause 6 of our Terms, we:

• process the personal data only on your documented instructions, which are our Terms and the way you set up your account and your tours, unless the law requires otherwise; and tell you if we think an instruction breaks data protection law (clause 6.3.1);
• make sure that everyone who processes it for us is bound to keep it confidential, and that our staff open your tours or files only to provide the service, fix a fault, look into a report or a suspected breach of our Terms, or because the law or a court requires it (clause 6.3.2);
• keep it secure with the measures in section 4, which we may improve but will not make weaker (clause 6.3.3);
• help you, as far as we reasonably can, to answer people who use their data protection rights, to keep the data secure, and with impact assessments and consultations with the ICO (clause 6.3.4);
• tell you of a request from a public authority for your content, unless the law forbids it (clause 6.3.5);
• give you the information you need to show that we keep to this agreement: we answer a reasonable security questionnaire once a year, and an audit by you, or by an auditor you choose who is bound to confidentiality, can be arranged on reasonable notice and at your cost (clause 6.3.6);
• use only the sub-processors in section 5, bound by data protection terms as protective as these, and tell you by email at least 30 days before we add or replace one that would process your content (clause 6.4);
• tell you of a personal data breach within 48 hours, as section 7 says (clause 6.5);
• delete the personal data at the end, as section 8 says (clause 6.8).

If we change clause 6 in a way that is worse for you, we tell you at least 30 days before, and you may end the plan or Vault concerned before the change (clause 6.7).

3. Details of the processing

4. How we keep it secure

• Everything between a browser and Panoramr is encrypted (HTTPS).
• Passwords are kept only as one-way codes (hashes), and a new password that has appeared in a known data breach is refused. Every account can turn on two-step sign-in, and our staff need a code as well as a password to sign in to our administration tools.
• The original photos you upload are private files that only your account can open. The position a camera or a phone writes into a photo is taken out of the files before they are stored, and is kept privately with the panorama for you alone.
• Your tours are seen only by the people you choose: a tour stays a private draft until you publish it, and a hosted tour can be kept to the people you send its link to, or to the people who know its password. The people you invite to work on a tour sign in with their own accounts.
• Our staff open your tours or files only for the reasons in section 2, and what they do in our administration tools is recorded.
• Every tour and our database are backed up each night to a separate store in another region of the European Union, so that a tour can be brought back after a mistake or a failure.
• Our servers keep logs of the requests they answer, normally for 14 days, to find faults and stop attacks. Logs never hold passwords or the contents of what you upload.

5. Sub-processors

Our sub-processors page lists every company that works for us, what each one does, what it receives, when, and where it handles the data. The ones that hold or carry your tours are DigitalOcean, which hosts our servers and stores the files, and Cloudflare, which delivers the pages and pictures to visitors. Emails are sent through Mailgun.

6. Where the data is

Your tours and files are stored in the United Kingdom and the European Union, as the sub-processors page says for each company, unless you choose another region for your files on your account's Data location page (the United States, Singapore or Australia, where open); your account and its records stay in the United Kingdom and the European Union either way. Some sub-processors are United States companies, and some data, such as an email address an email is sent to, may reach the United States. Where personal data goes to a country the UK has not found to protect it adequately, we use a safeguard the UK recognises, as section 6 of our Privacy Policy says. You can ask us for a copy of the safeguard for any of them.

7. If something goes wrong

If we become aware of a breach of security that affects personal data we process for you, we tell you without undue delay and in any case within 48 hours, with what happened, its likely effects, what we are doing about it and who you can contact, and we tell you more as we learn it. That gives you time to tell the ICO within the 72 hours the law allows you. Attempts that fail and expose nothing, such as blocked sign-ins, are not reported.

8. At the end

You can download your tours at any time while your account is open, so download what you want to keep before you close it. When an account is closed it is taken offline at once and kept for 30 days, so that it can be restored if it was closed by mistake. Then your tours, files and account are deleted. Backup copies are deleted on their own cycle: the copies of the tours of a deleted account 30 days after it is deleted, and the nightly copies of our database within four weeks. Records we must keep by law, such as invoices, are kept for six years, as our Privacy Policy says.

9. People using their rights

If somebody asks us about personal data in one of your tours, we pass the request to you, unless it is a report about the tour, which we handle ourselves as our Terms say. Anyone who appears in a tour can ask for it to be blurred or removed with the form at /report. You can blur faces and other details in your own panoramas at any time, and change or delete your tours.

10. Questions

If you have a question about this agreement, need something for your records, or want our answers to a security questionnaire, write to us at moc.rmaronap@tcatnoc. Our safeguarding statement says what we do about tours that show children or vulnerable adults.