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Data processing addendum

The terms under which Buun Group Pty Ltd processes personal data for a workspace that uses Flung, as Article 28 of the GDPR (General Data Protection Regulation) and the UK GDPR require. It forms part of the terms of service and applies whenever Flung processes personal data on a workspace's behalf.

Last updated: 2026-10-31

This is Flung's standard data processing addendum. It applies without a signature, from the day a workspace accepts the terms of service. If your organisation needs a copy signed by both sides, write to legal@buungroup.com (opens in a new tab) with the workspace's name and your organisation's legal name, and we send one back countersigned.

TL;DR

QuestionAnswer
Who is who?Your organisation, as the customer, is the controller. Buun Group Pty Ltd, ABN 75 687 193 675, Australia, which runs Flung, is the processor.
What does Flung process?The personal data in your workspace: your team's sign-in details, the social accounts people connect, the posts, files and comments, and the webhooks and keys you set up.
What for?Only to publish, schedule and report on what your workspace asks for, and to keep the service secure.
Who helps us?The providers on the subprocessors page, with notice before a new one starts.
What if there is a breach?We tell you without undue delay after we become aware of it.
What happens at the end?Your data is deleted as the data deletion page describes, or returned to you first if you ask.
How is data sent outside its region covered?By the EU Standard Contractual Clauses and the UK Addendum, which this addendum includes.
How do I get a signed copy?Write to legal@buungroup.com (opens in a new tab).

The parties and their roles

PartyRole
The customer: the organisation or person that owns the workspace and accepted the terms of serviceController. It decides why personal data is processed in its workspace, and is responsible for having a lawful basis to do so, including for the people who connect accounts through its own product.
Buun Group Pty Ltd, ABN 75 687 193 675, Spring Mountain, QLD 4300, Australia ("Buun Group", "we")Processor. It processes the customer's personal data only on the customer's documented instructions.

Where the customer is itself a processor for someone else, Buun Group is its subprocessor, and the customer passes on the instructions of its own controller.

For the personal data of the people who sign in to Flung, used to run their accounts, bill the workspace and keep the service secure, Buun Group is a controller in its own right, as the privacy policy says. This addendum does not cover that data.

Details of the processing

ItemDetail
Subject matterThe provision of Flung: the API, the portal, the connect panel, the SDKs and the hosted MCP server.
DurationFor as long as the workspace exists, and after that until its data is deleted as the deletion section below describes.
NatureStoring, organising, retrieving, transmitting to the platforms and endpoints the customer chooses, and deleting.
PurposeTo connect social accounts, publish and schedule posts, store media, read comments and mentions where the inbox is on, report results, send webhook events, and keep the service secure and within its limits.
Types of personal dataWorkspace members' email addresses, names, mobile numbers and countries where given. Connected social accounts' ids, usernames, display names, picture addresses, and access and refresh tokens. The content of posts, and the images and videos attached. Comments on and mentions of a connected account, with their authors' ids, names and handles. Brand names and the customer's own ids for them. Webhook addresses. Request logs with IP addresses.
Categories of data subjectsThe customer's workspace members. The people who connect a social account through the customer's workspace or product. The people who comment on or mention a connected account. Anyone named or shown in the content the customer posts.
Special categoriesNone are required. The customer should not send special category data (such as health data) through Flung unless its own lawful basis covers it.

The customer's instructions

The customer's instructions are these terms, the terms of service, and what the customer does in Flung: the calls its keys and apps make, and what its members do in the portal. Buun Group processes the personal data only on those instructions, unless the law requires otherwise, in which case it tells the customer first unless the law forbids that. Buun Group tells the customer if it believes an instruction breaks data protection law.

What the processor commits to

DutyWhat it means
ConfidentialityEveryone at Buun Group who can reach the personal data is bound to keep it confidential. Staff reach it only through the staff console, which never shows a token, a key's secret part, a webhook secret or a post's media, and records every action with a typed reason.
SecurityBuun Group keeps the technical and organisational measures the next section summarises, appropriate to the risk.
SubprocessorsBuun Group engages subprocessors only as the subprocessors section says.
Help with requestsBuun Group helps the customer answer the requests of data subjects, as the section on rights requests says.
Help with complianceBuun Group gives the customer the information it reasonably needs for a data protection impact assessment or a consultation with a supervisory authority, about the processing Flung does.
No other useBuun Group does not sell the personal data, use it for advertising, or use it to train AI models.

Security measures

Buun Group protects the personal data with, among others, these measures. The security page describes each in full.

  • Every connection to Flung is encrypted in transit with TLS.
  • Platform tokens, webhook signing secrets and integration credentials are encrypted in the database with AES-256-GCM, under a key kept for each environment and held apart from the database.
  • Sign-in codes, session cookies and API keys are stored only as hashes.
  • People sign in with a single-use emailed code, or with Google or GitHub. Sign-in, app approval and deletion forms are checked by Cloudflare Turnstile.
  • Each workspace's data is reachable only with that workspace's credentials, and only owners may change its plan or delete it.
  • The workspace's activity log, and the staff log of every staff action, record who changed what.
  • The service runs on Cloudflare's infrastructure, which keeps the database's restore history.

Subprocessors

The customer gives general authorisation for Buun Group to engage subprocessors. The current ones, what each does and where, are on the subprocessors page.

RuleDetail
NoticeBuun Group adds a new subprocessor to that page at least 30 days before it receives personal data, and emails customers who asked to be told.
ObjectionThe customer may object on reasonable data protection grounds within that time. If the parties cannot agree a way forward, the customer may end the affected service and receive a refund of any month paid for and not used.
Same dutiesBuun Group puts each subprocessor under data protection duties no less protective than these, and remains responsible to the customer for its subprocessors' performance.

The social platforms the customer posts to are not subprocessors: they are destinations the customer chooses, as the subprocessors page explains.

Rights requests

Data subjects may ask to access, correct, delete, restrict or move their personal data, or object to its use. Most of these the customer can answer itself in Flung: it can read a workspace's data through the API, disconnect an account, delete a post, a file or a brand, and delete the workspace.

When Buun Group receives a request about the customer's data directly, it passes it on to the customer without undue delay and does not answer it itself, unless the customer asks it to or the law requires it. Where the customer cannot answer a request with Flung's own tools, Buun Group helps, taking into account the nature of the processing.

Breach notification

If Buun Group becomes aware of a breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to the customer's personal data, it tells the customer without undue delay, at the email addresses of the workspace's owners. The notice says, as far as is known then, what happened, the kinds and rough number of people and records affected, the likely consequences, and what Buun Group has done and proposes to do. More follows as it becomes known. Telling the customer is not an admission of fault.

Deletion or return at the end

When a workspace is deleted, Flung decommissions it at once and deletes it, with its accounts, posts, files and keys, 14 days later, as the data deletion page describes. Before deleting it, the customer may read its data out through the API, or ask legal@buungroup.com (opens in a new tab) for a copy, which Buun Group provides as an export in a common machine-readable format within 30 days.

A deleted record can remain for a limited time in the database's restore history, which Cloudflare keeps and which expires on its own. Buun Group keeps personal data after the end only where the law requires it, and then only for that purpose.

Audits

Buun Group makes available to the customer the information needed to show that it meets these terms. The customer may send a written questionnaire up to once a year, which Buun Group answers in reasonable time, and may rely on the reports of Buun Group's subprocessors, such as Cloudflare's certifications. Where that is not enough, or a supervisory authority asks, the customer may carry out an audit, or have an independent auditor bound to confidentiality carry it out, on 30 days' notice, during business hours, at the customer's cost, and in a way that does not put other customers' data at risk.

International transfers

Buun Group is in Australia, and Flung runs on Cloudflare's global network, so personal data may be processed in Australia and in other countries where Cloudflare and the other subprocessors operate.

FromHow the transfer is covered
The European Economic AreaThe Standard Contractual Clauses adopted by the European Commission in Decision 2021/914, Module Two (controller to processor), or Module Three where the customer is a processor, are included in this addendum by reference. The details they ask for are in the section on the details of the processing above. Clause 7 (the docking clause) applies, the option in Clause 9(a) is general authorisation with the notice above, Clause 11's optional wording does not apply, and Clauses 17 and 18 choose the law and courts of Ireland.
The United KingdomThe International Data Transfer Addendum to the EU Standard Contractual Clauses, issued by the Information Commissioner, is included in this addendum by reference, with the details above.
SwitzerlandThe Standard Contractual Clauses above, read with the Swiss Federal Act on Data Protection in place of the GDPR where it applies.

Each subprocessor's own safeguards for the transfers it makes are described in its terms, linked from the subprocessors page. Where the Standard Contractual Clauses conflict with this addendum, the Clauses win.

Australian privacy law

Buun Group handles personal information in line with the Privacy Act 1988 and the Australian Privacy Principles. Where an eligible data breach under that Act affects the customer's data, Buun Group also meets the notification duties the Notifiable Data Breaches scheme sets.

Liability

Each party's liability under this addendum, and under the Standard Contractual Clauses where the law allows it, is subject to the limits in the liability section of the terms of service. Nothing here limits a data subject's own rights under the Clauses or under data protection law.

Order of precedence

Where this addendum and the terms of service differ about personal data, this addendum wins. Where a signed contract between the customer and Buun Group differs from both, the signed contract wins.

See also

PageWhy
SubprocessorsThe providers that handle personal data for Flung
SecurityThe measures that protect the data
Data deletionWhat is deleted, how, and when
Privacy policyThe personal data Flung collects as a controller, and your rights
Terms of serviceThe agreement this addendum is part of
Cookie policyThe cookies and browser storage on each Flung site
Acceptable use policyWhat Flung may not be used for