Data controllership
PayAtt AB is the data controller for end-customer data. You who run the venue never see individual phone numbers or other individual PII — instead you work with overall statistics, campaign history, and smart filters that let you segment your members (e.g. "everyone who hasn't visited in 30 days"). The system then performs the send without exposing individual numbers to you. That is why you don't need a separate Data Processing Agreement with us — you are not a data processor because you never handle individual PII. We in turn have sub-processor agreements (DPAs) with our vendors (Stripe, AWS, sms-gateway, etc.) — that is where end-customer data is actually protected.