Draft. Not yet in effect.

Data Processing Addendum

Last updated: [OWNER: date]

1. Roles

For room content, the customer is the controller and [OWNER: legal entity name] is the processor. For billing and account data about organizers, we act as an independent controller as described in the Privacy Policy.

2. Documented instructions

We process room content only on the customer's documented instructions, which are these terms, the Terms of Service, and the customer's use of the product settings. We tell the customer if we believe an instruction breaks the law.

3. Subprocessors

We will tell customers before adding or replacing a subprocessor. [OWNER: notice period and objection process.]

4. Security measures

5. Personal data breach

We will notify the customer without undue delay and within [OWNER: hours, for example 72] hours after we become aware of a breach affecting their room content, with the information we have about it.

6. Confidentiality and staff

People who can access room content are bound by confidentiality duties and access it only as needed to run the service.

7. Deletion on termination

When the customer deletes a room, we delete its data. When the agreement ends, we delete remaining room content on request, and backups expire within 30 days.

8. Audits

On reasonable request, we will give the customer the information needed to show we meet this addendum, and we will cooperate with reasonable audits. [OWNER: audit frequency and cost terms.]

9. International transfers

[OWNER: where data is processed and the transfer mechanism, if any.]

10. Contact

Questions about this addendum: support@virtualoffsite.com.