Data Processing Addendum

Scope and roles

This addendum applies where NotifHQ processes personal data on behalf of a customer in providing the service. In that processing the customer is the controller and NotifHQ is the processor.

It forms part of the Terms of Service and takes effect when a workspace is created. Where it conflicts with the Terms of Service on the subject of processing personal data, this addendum prevails.

Subject matter, duration, nature and purpose

Subject matter: the delivery of customer communications and the records of that delivery. Duration: for as long as the workspace exists, plus the retention windows in the Privacy Policy. Nature and purpose: rendering messages from customer-supplied templates and parameters, carrying them to the destinations the customer names, recording the outcome, and enforcing the preferences and suppressions the customer or the recipient has set.

Categories of data and of data subject

Data subjects: the customer's own end users, employees and contacts — the recipients of the messages the customer sends.

Personal data: contact identifiers (email address, phone number, device token, external identifier), message content supplied by the customer, delivery and engagement metadata, preference and suppression state, and the contents of inbound messages a recipient sends to a workspace.

The customer decides what enters message parameters. Special-category data may be processed where the customer's own configuration places it there, and the platform's redaction and purpose-of-use controls apply to it; the customer remains responsible for the lawfulness of placing it there.

Our obligations

• We process personal data only on the customer's documented instructions, of which the API calls made with the customer's key and the configuration held in the workspace are the principal form.
• We require confidentiality of everyone we authorise to process it.
• We keep the technical and organisational measures described on the security page, and do not reduce them below what is described there.
• We assist the customer in responding to a data subject's request, and in meeting the obligations that follow a personal data breach or a data protection impact assessment.
• We notify the customer without undue delay after becoming aware of a personal data breach affecting their data, with what we know at the time rather than waiting for a complete picture.
• On the customer's instruction at the end of the service we delete their personal data, except where we are legally required to keep it.
• We make available the information needed to demonstrate compliance and submit to an audit, on reasonable notice and no more than once a year unless a supervisory authority or a breach requires otherwise.

Sub-processors

The customer gives general authorisation for the sub-processors listed on the sub-processors page. We impose on each of them data protection obligations no less protective than these, and we remain liable for their performance.

We will give notice before adding or replacing a sub-processor. A customer who objects on reasonable data protection grounds within 30 days may terminate the affected part of the service without further charge.

International transfers

Personal data is stored in the United States. Where it originates in the United Kingdom or the European Economic Area, the transfer relies on the European Commission's Standard Contractual Clauses (Module Two, controller to processor), completed with the details in this addendum, and on the UK International Data Transfer Addendum where the UK GDPR applies.

The parties agree that the Standard Contractual Clauses are incorporated into this addendum by reference and that, where they conflict with it, they prevail.

Deletion and return

A recipient's erasure is executed by the platform rather than promised by it: the erasure plane resolves every table holding that recipient's data and carries out the disposition recorded against each, and the evidence of having done so is written to an append-only record.

At the end of the service the customer may export their data through the compliance export before the workspace is closed.

Contact

Questions about this addendum, and requests for a signed copy: privacy@notifhq.com.