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Mojeek Search API Data Processing Agreement (DPA)

Version: 3.0 (5th November 2026)

This Data Processing Agreement (“DPA”) is between Mojeek Limited, a company registered in England under number 06918197, whose registered address is 74 High Street, Croydon, CR9 2UU, United Kingdom (“Mojeek”), and the customer that has accepted the Mojeek Search API Terms of Service Agreement (the “Customer”). It forms part of that agreement (the “API Terms”) and takes effect when the Customer accepts the API Terms.

Background

  1. Mojeek operates an independent search engine with its own index and provides the Search API, through which the Customer submits Search Queries and receives Search Results.
  2. A Search Query may contain Personal Data. This can include Personal Data about third parties named in the query and Special Category Data, such as a health condition. The parties acknowledge that receiving, using, matching, transmitting and erasing a Search Query is Processing, even when the query is held only in volatile memory and never written to storage.
  3. Mojeek does not receive or record End User IP addresses or End User identifiers, and it cannot identify the End User who originated a Search Query. Under Article 11 of the UK GDPR, Mojeek is not required to obtain additional information in order to identify an End User.
  4. This DPA sets out the terms on which Mojeek processes Query Data as the Customer’s Processor, as required by Article 28 of the UK GDPR and, where it applies, the EU GDPR.

1. Definitions

1.1 In this DPA:

  • “Applicable Data Protection Law” means the UK GDPR and the Data Protection Act 2018 (each as amended, including by the Data (Use and Access) Act 2025) and, where it applies to the Processing, the EU GDPR.
  • “End User” means any natural person on whose behalf, or as a result of whose activity, the Customer submits a Search Query.
  • “Query Data” means the content of each Search Query and the request parameters submitted with it, together with any Personal Data contained in them.
  • “Search Query” means a request submitted to the Search API by or on behalf of the Customer.
  • “Search Results” means the data returned by the Search API in response to a Search Query.
  • “Standard Retention” and “Zero Data Retention” have the meanings given in clause 4.
  • “Controller”, “Processor”, “Data Subject”, “Personal Data”, “Personal Data Breach”, “Processing”, “Special Category Data” and “Sub-processor” have the meanings given in Applicable Data Protection Law.

1.2 References to Articles are to the UK GDPR and, where the EU GDPR applies, also to the equivalent Article of the EU GDPR.

2. Scope and roles

2.1 Mojeek as Processor. For the Processing of Query Data described in Annex 1, the Customer is the Controller (or a Processor acting for another Controller) and Mojeek is the Processor.

2.2 Customer acting as Processor. Where the Customer acts as a Processor for another Controller, Mojeek acts as the Customer’s Sub-processor. In that case, instructions from the Customer include instructions the Customer gives on that Controller’s behalf.

2.3 Mojeek as independent Controller. The following Processing is outside the scope of this DPA. For it, Mojeek is an independent Controller, and it is described in Mojeek’s Privacy Policy:

  1. crawling the web and building, organising, ranking and maintaining Mojeek’s search index, and selecting and providing Search Results, including any Personal Data contained in indexed web content and returned in Search Results; and
  2. Processing Personal Data about the Customer and its staff for account registration and administration, billing, payment, tax, customer support, the security of Mojeek’s systems, the prevention of fraud and abuse, and compliance with Mojeek’s legal obligations. None of these purposes involves Processing the content of Query Data.

2.4 Search Results after delivery. Once Search Results are delivered to the Customer, any further Processing of them by the Customer is the Customer’s own Processing, for which the Customer is the Controller.

2.5 Customer responsibilities. The Customer is responsible for:

  1. having a lawful basis for the Processing of Query Data, and an Article 9 condition where Query Data includes Special Category Data;
  2. giving End Users any information required by Articles 13 and 14; and
  3. ensuring that its instructions comply with Applicable Data Protection Law.

3. Instructions and purpose limitation

3.1 Mojeek will Process Query Data only on the Customer’s documented instructions. The Customer’s instructions are:

  1. the API Terms and this DPA;
  2. the Customer’s choice of plan and retention option; and
  3. any further written instruction agreed between the parties.

Those instructions are to Process Query Data in order to execute Search Queries, return Search Results and retain Query Data as set out in clause 4.

3.2 If Mojeek is required by law to Process Query Data other than on the Customer’s instructions, it will inform the Customer of that requirement before the Processing, unless the law prohibits this on important grounds of public interest.

3.3 Mojeek will inform the Customer immediately if, in its opinion, an instruction infringes Applicable Data Protection Law.

3.4 Mojeek will not:

  1. use Query Data for its own purposes. This includes improving, ranking or extending its index; analytics; profiling; advertising; and training or evaluating any machine-learning model;
  2. sell, rent or disclose Query Data to any third party, except as permitted by clause 11;
  3. combine Query Data with Personal Data from any other source; or
  4. attempt to identify any End User or other natural person from Query Data.

4. Retention of Query Data

4.1 Standard Retention. Standard Retention applies by default. Unless the Customer has selected Zero Data Retention under clause 4.2:

  1. Mojeek retains Query Data for up to 90 (ninety) days solely to diagnose and fix faults and to verify the correct operation of the Search API. Retention for this purpose is part of providing the service to the Customer.
  2. Retained Query Data consists of the query string, request parameters, timestamp and the API key used to submit the request. The API key is retained only so that Mojeek can identify which Customer’s traffic a fault affects and, on request, locate or delete that Customer’s retained Query Data.
  3. Retained Query Data is accessible only to Mojeek personnel who need it for that purpose. It is not copied into analytics, customer-support, backup or model-training systems.
  4. Retained Query Data is deleted automatically at the end of the retention period.

4.2 Zero Data Retention. Zero Data Retention is an optional setting available on specific plans. It applies only where the Customer has selected it. Where it applies, Query Data is held only in volatile memory for as long as it takes to execute the Search Query and return the Search Results. It is then discarded, and it is not written to any log or persistent storage.

4.3 Connection and billing data. Under every plan:

  1. Mojeek does not receive or record End User IP addresses or End User identifiers.
  2. The IP address of the system connecting to the Search API, which is normally the Customer’s server, may be used for routing, security and rate limiting, and is not retained.
  3. For billing, Mojeek records usage counts against the Customer’s account. Billing records do not contain Query Data.

4.4 Aggregate metrics. Mojeek may keep aggregate technical metrics, such as request volumes, latency and error rates, only where they contain no Query Data and cannot reasonably be linked to any natural person.

4.5 Pseudonymised data. Pseudonymised or hashed values derived from Query Data are treated as Query Data under this DPA.

5. Confidentiality

5.1 Mojeek will ensure that everyone it authorises to Process Query Data is bound by an appropriate contractual or statutory duty of confidentiality, and has access only where necessary for the purposes in clause 4.1.

6. Security

6.1 Mojeek will implement and maintain the technical and organisational measures described in Annex 2. Those measures meet the requirements of Article 32, taking into account the state of the art, the cost of implementation, the nature, scope, context and purposes of the Processing, and the risks to Data Subjects.

6.2 Mojeek may update those measures, provided the overall level of protection is not reduced.

7. Sub-processors

7.1 The Customer gives Mojeek general authorisation to engage the Sub-processors listed in Annex 3.

7.2 At the date of this DPA, no Sub-processor has access to, or Processes, Query Data.

7.3 Mojeek will give the Customer at least 30 days’ written notice of any intended addition or replacement of a Sub-processor. If the Customer objects on reasonable data protection grounds within that period and the parties cannot resolve the objection, the Customer may terminate the API Terms without penalty.

7.4 Mojeek will impose on each Sub-processor, by written contract, data protection obligations equivalent in substance to those in this DPA. Mojeek remains fully liable to the Customer for each Sub-processor’s performance.

8. Processing location and international transfers

8.1 Mojeek Processes Query Data only in the United Kingdom, on servers it owns and operates.

8.2 Mojeek will not transfer Query Data outside the United Kingdom except on the Customer’s documented instructions or where required by law. Any such transfer will be made under UK adequacy regulations or the UK International Data Transfer Agreement or Addendum, together with a transfer risk assessment.

8.3 Where the Customer is subject to the EU GDPR, the parties acknowledge that transfers of Query Data from the Customer to Mojeek are covered by the European Commission’s adequacy decision for the United Kingdom.

9. Assistance

9.1 Data Subject requests. If Mojeek receives a request from a Data Subject relating to Query Data, it will promptly forward the request to the Customer where the Customer can be identified, and will not respond except on the Customer’s instructions.

9.2 Limits of Data Subject assistance. Mojeek cannot identify End Users (Background C). The Customer acknowledges that Mojeek’s assistance with Data Subject requests is therefore limited to what is technically possible, for example locating and deleting retained Query Data submitted under the Customer’s API key that matches information the Customer provides.

9.3 Other assistance. Taking into account the nature of the Processing and the information available to it, Mojeek will reasonably assist the Customer with its obligations under Articles 32 to 36, including data protection impact assessments and prior consultation with a supervisory authority.

10. Personal Data Breaches

10.1 Mojeek will notify the Customer without undue delay, and in any event within 48 hours, after becoming aware of a Personal Data Breach affecting Query Data.

10.2 The notification will include, so far as the information is available:

  1. the nature of the breach and the categories and approximate volume of data affected;
  2. a contact point for further information;
  3. the likely consequences; and
  4. the measures taken or proposed to address the breach and mitigate its effects.

10.3 Where Mojeek cannot provide all of this information at once, it will provide further information without undue delay as it becomes available.

11. Requests from public authorities

11.1 If Mojeek receives a legally binding request from a public authority for Query Data, it will:

  1. notify the Customer promptly, unless the law prohibits this;
  2. assess whether the request is lawful and challenge it where there are reasonable grounds to do so; and
  3. disclose only the minimum Query Data required.

11.2 Mojeek will include such requests in its transparency reporting, as described in its content policy.

11.3 Where Zero Data Retention applies, Mojeek holds no Query Data capable of disclosure.

12. Information and audit

12.1 Mojeek will make available to the Customer the information reasonably necessary to demonstrate compliance with this DPA and Article 28. This includes a description of the controls in clause 4 and Annex 2.

12.2 If that information is reasonably insufficient, the Customer, or an independent auditor bound by confidentiality and mandated by the Customer, may audit Mojeek’s compliance. Any such audit:

  1. may take place no more than once in any 12-month period, unless required by a supervisory authority or following a Personal Data Breach;
  2. requires at least 30 days’ written notice;
  3. must take place during normal business hours and in a manner that does not compromise the security or confidentiality of Mojeek’s systems or other customers; and
  4. is at the Customer’s cost.

13. Deletion at termination

13.1 On termination or expiry of the API Terms, Mojeek will delete all Query Data it holds for the Customer within 30 days, or earlier where clause 4 requires earlier deletion, unless the law requires retention. Mojeek will confirm deletion in writing on request.

13.2 The Customer already holds the Search Queries it submitted, so the parties agree that deletion, rather than return, satisfies Article 28(3)(g).

14. Liability

14.1 Each party’s liability under or in connection with this DPA is subject to the exclusions and limitations of liability in the API Terms, which apply to this DPA.

14.2 Nothing in this DPA limits either party’s liability where the law does not allow it to be limited, or limits any rights of Data Subjects under Applicable Data Protection Law.

15. General

15.1 Term. This DPA remains in force for as long as Mojeek Processes Query Data for the Customer.

15.2 Precedence. If there is a conflict between this DPA and the API Terms on the Processing of Personal Data, this DPA prevails.

15.3 Changes. Mojeek may update this DPA:

  1. to reflect changes in Applicable Data Protection Law; or
  2. in ways that do not reduce the protection given to Query Data.

It will give at least 30 days’ notice of material changes, in line with the API Terms.

15.4 Governing law. This DPA is governed by the law of England and Wales. The courts of England and Wales have exclusive jurisdiction.

Annex 1: Description of the Processing

Item Description
Controller The Customer (or the Controller for which the Customer acts as Processor).
Processor Mojeek Limited, 74 High Street, Croydon, CR9 2UU. Contact: privacy@mojeek.com
Subject matter Execution of Search Queries submitted to the Mojeek Search API.
Nature of Processing Receipt, parsing, matching against Mojeek’s index, return of Search Results, erasure; and, under Standard Retention, temporary storage for fault diagnosis.
Purpose Providing the Search API to the Customer, and diagnosing and fixing faults in it.
Categories of Data Subjects End Users; natural persons named or described in Search Queries.
Categories of Personal Data Whatever Personal Data the Customer or its End Users include in Search Queries, such as names, contact details, locations and other free text. Mojeek does not receive or record End User IP addresses or identifiers.
Special Category Data May be present in free-text Search Queries (for example, health-related searches). It is not requested by Mojeek and is subject to the same controls as all other Query Data.
Frequency Continuous, per request.
Duration Standard Retention: up to 90 days. Zero Data Retention: the duration of the request only.
Location United Kingdom only.

Annex 2: Technical and organisational measures

  1. Infrastructure: Query Data is processed only on servers owned outright by Mojeek and operated solely by Mojeek, colocated at Custodian Data Centres, Maidstone, United Kingdom. No public cloud, rented or shared server hosts or processes Query Data.
  2. No third-party access: No third party, Sub-processor or external service receives Query Data. The data centre operator provides power, cooling, connectivity and physical security, and has no logical access to Mojeek’s servers. The search engine, including crawling, indexing, ranking and API serving, is developed and operated in-house.
  3. Encryption in transit: The Search API is available only over TLS 1.2 or higher.
  4. Retained Query Data (Standard Retention): held on access-restricted production servers, deleted automatically after 90 days, and not copied to any other system.
  5. Administrator authentication: Access to production servers is limited to Mojeek development staff, using SSH certificates signed by a Mojeek-controlled certificate authority. Certificates are time-limited, scoped by role, and can be revoked. Password authentication and root login are disabled.
  6. Access to retained Query Data: retained Query Data is held on a single internal server, and only Mojeek administrators can access it. Administrator access is granted only to staff who need it. Logins to production servers are recorded in system authentication logs.
  7. Logging: Production logs do not record End User IP addresses or End User identifiers. Under Zero Data Retention, no Query Data is written to any log.
  8. Personnel: Staff are bound by confidentiality obligations and given access on a need-to-know basis.
  9. Physical security: provided by Custodian Data Centres, which holds ISO/IEC 27001:2022 certification, through an access-controlled, monitored facility.
  10. Hardware disposal: storage media from decommissioned servers remain in Mojeek’s custody until they are securely wiped or physically destroyed, and are never sold, reused by third parties or disposed of intact.
  11. Incident response: Mojeek maintains a documented procedure for detecting, containing, investigating and notifying Personal Data Breaches in line with clause 10.

Annex 3: Authorised Sub-processors for Query Data

None. No Sub-processor has access to, or Processes, Query Data.