Data Processing Agreement

The roles

For the renter data you keep in the panel YOU are the controller, and the company is a processor acting only on your instructions.

For your own account, subscription and invoice data the company is the controller, and the rules for that are in the Privacy Policy.

This agreement is governed by the law of the State of Delaware. Complying with the data protection law of your own country, and your duties to your own customers, are yours as the controller.

Subject, duration and nature of the processing

Subject: storing, displaying, backing up and, on your request, exporting booking, driver and payment records.

Categories: your renter's identity, contact details, licence details and booking information, together with payment status.

Duration: for as long as the subscription lasts, plus the thirty day export window after it ends.

Managing your domain is part of this: the domain is registered in your name and the account at your registrar stays yours; pointing its nameservers at the company is the authority to manage, on your behalf and for the life of the subscription, the DNS records the service needs - the site, the content delivery and the e-mail routing. Messages passing through that routing are processed under this agreement. When the subscription ends the zone is kept for thirty days; within that window the nameservers may be pointed at any other provider, and at the end of it the record is removed from the company's infrastructure.

Instructions and confidentiality

Data is processed only on your instructions and within this agreement. Where the law requires processing, you are told first unless telling you is prohibited.

Staff with access are under a duty of confidentiality and access is limited by role.

Your data is separated per tenant so that it cannot be mixed with another customer's.

Sub-processors

Sub-processors are used to run the service. The current list is published on the Privacy Policy page with each one's name, function and region.

You are told a reasonable time before a new sub-processor is added and you may object on reasonable grounds.

Written agreements with sub-processors carry obligations equivalent to those in this agreement.

Security measures and breach notification

TLS in transit, encryption for backups, role based access, an audit log and regular backups are in place.

If a personal data breach is discovered you are told without undue delay, with the nature of the breach, the categories affected and the measures taken.

No numeric deadline is promised for that notice: the measure is without undue delay once the breach is discovered.

Return, deletion and audit

When the subscription ends the data stays exportable for thirty days, and is deleted for good at the end of that window once the backup cycle has rolled over.

On request, written confirmation of the deletion is provided.

An audit may be requested once a year and within a reasonable scope. Where an independent audit report exists, that report answers the request.