Which document applies
The two EU clause sets serve different jobs. Decision 2021/915 supplies controller–processor clauses under GDPR Article 28 and is relevant to AskAgain processing customer content. Decision 2021/914 supplies modular safeguards for transfers to recipients outside the EEA when no other Chapter V mechanism applies. Customer location alone does not decide which document is needed.
Completing the agreement
The official clauses require completed annexes covering the customer/controller and VHUG Technologies OÜ/processor identities; subject, duration, nature and purpose; data subjects and data types; instructions; security measures; subprocessors; and, for international transfers, the correct module and transfer assessment. Request the completed AskAgain DPA and applicable annexes from support.
Report-translation subprocessor
DeepL SE, Maarweg 165, 50825 Cologne, Germany, processes report content only when a translation is requested. VHUG Technologies OÜ has procured DeepL’s signed Article 28 processing agreement for this processing.