Terms, exit plan and pre-contract information compliant with the Data Act.
§ 1
Approach
The Regulation allocates obligations according to whether you provide data processing services, manufacture connected products or hold data. We settle that before touching a clause.
Notice periods, lock-ins, migration charges and export formats. We mark what has not held since September 2025 and what falls on 12 January 2027.
A departing customer and the authority ask the same thing: what is handed over, in what format and within what time. The exit plan answers before they ask.
§ 2
Engagement
El importe exacto se cierra en la hoja de encargo antes de pagar, con los gastos previsibles incluidos. Si el encargo se alarga, no pagas más.
§ 3
Process
A unilateral confidentiality agreement signed by PASSAS before the video consultation, available at no additional cost on request. It binds the firm alone — no signature is required from the client — and adds an explicit contractual layer on top of the professional secrecy obligations inherent to the practice of law.
A 60-minute working session by video call in which we analyse your situation, your specific needs and our ability to help you. We assess whether we can take on the matter and give you the fixed price in advance. You can book it directly through the Google Calendar link on our website and pay €90 by Stripe.
An analysis of the company's position under Regulation (EU) 2023/2854 (provider of data processing services, manufacturer of connected products or data holder) and of the obligations and dates that apply in each role. It reviews the current terms clause by clause, marks those that lose validity and sets the adaptation timetable up to 12 January 2027.
Service terms rewritten for switching: maximum notice period, transitional period, exportable data and export format, removal of switching charges, and data access and use clauses that withstand the unfairness test. Includes the addendum for customers who signed before the change.
A documented switching and export procedure (what is handed over, in what format, with what assistance and within what time limits), together with the information article 29 requires before signature and on the website.
§ 4
Team
I see legal practice as a discipline of precision. I work where the law meets technology and cross-border operations, and I read code and contracts with the same attention. Before accepting an engagement I tell you whether it is worth pursuing and what it costs, at a fixed price.
§ 5
Questions
Anyone providing data processing services to customers in the Union (SaaS, PaaS and IaaS), wherever they are established. Establishing whether your service falls within that definition and which exceptions may apply is the first part of the engagement.
The switching rules have applied since 12 September 2025, and 12 January 2027 removes any charge for leaving. The unfair terms test in Chapter IV reaches earlier contracts on 12 September 2027. The engagement includes the addendum to bring your existing customer base into line.
Until 12 January 2027 only the direct cost of the exit may be passed on, and from that date none at all (article 29). Anything invoiced today as a ‘migration service’ above that cost is already a problem.
From €4,500 + VAT, delivered within three weeks. The exact figure is fixed in the engagement letter before you pay, and depends on the number of products and contract templates to be adapted.
60 minutes on Google Meet with a qualified lawyer specialising in artificial intelligence, data, litigation or international law. €90 including VAT, deducted from the first invoice if we take on your matter. You leave with legal judgement and a fixed price for whatever comes next.
