Data Processing Agreement
This Data Processing Agreement (“DPA”) applies to property managers and trade partner businesses (“Customer”) who process personal data of third parties (such as property owners or tenants) through Crawl-Space Connect (the “Service”). By using the Service in a business capacity that involves third-party personal data, Customer enters into this DPA with Crawl-Space Connect LLC (“Crawl-Space Connect” or “Processor”).
1. Roles
For personal data processed through the Service, Customer is the controller (or processor acting on behalf of its own controller) and Crawl-Space Connect is the processor (or sub-processor). Crawl-Space Connect processes personal data only on documented instructions from Customer, including those instructions embedded in the Service itself (such as the permissioned access flows).
2. Scope
| Item | Detail |
|---|---|
| Subject matter | Provision of the Service per the Terms |
| Duration | Term of the underlying subscription |
| Nature and purpose | Operation of a property records registry |
| Categories of data | Account data, property data, Crawlspace Blueprints™ media, record content, activity data |
| Categories of data subjects | Property owners, property managers, trade partner personnel |
3. Sub-processors
Crawl-Space Connect maintains the list of sub-processors in the Privacy Policy. Customer authorizes the engagement of those sub-processors. Crawl-Space Connect notifies Customer of material changes at least 30 days in advance; Customer may object on reasonable grounds.
4. Security
Crawl-Space Connect maintains the safeguards described in the Privacy Policy (Section 11) and the Security and Access page. Customer is responsible for the security of its own account credentials and the permissions it grants.
5. International transfers
Where required, Crawl-Space Connect relies on Standard Contractual Clauses (and the UK IDTA where applicable) with sub-processors. The relevant SCC modules are incorporated by reference.
6. Audit
Customer may request a summary of Crawl-Space Connect's most recent security review or equivalent documentation, once per 12-month period, subject to a confidentiality undertaking. Customer may request a deeper audit at Customer's cost where required by law.
7. Data subject requests
Crawl-Space Connect provides Customer with the means within the Service to respond to data subject requests for access, correction, deletion, and portability. Crawl-Space Connect assists Customer with such requests where reasonably necessary.
8. Breach notification
Crawl-Space Connect notifies Customer of any security incident affecting Customer data without undue delay, and where feasible within 72 hours of becoming aware. The notification will include the information reasonably available to Crawl-Space Connect at the time.
9. Return or deletion on termination
On termination, Customer may export its data via the Service for 30 days. After the export period, Crawl-Space Connect retains data per the retention schedule in the Privacy Policy, or deletes it where required by Customer's documented instructions and applicable law.
10. Contact
crawlspaceconnect@gmail.com
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