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Data Processing Agreement
This Data Processing Agreement forms part of, and is automatically incorporated into, the Terms of Service between Caprisol, trading as findbl. ("Processor") and you ("Controller") from the moment your subscription begins, per Article 28 GDPR. No separate signature is required.
1. Subject and duration — governs Processor's processing of personal data on Controller's behalf, for as long as the Terms of Service remain in effect.
2. Nature and purpose — hosting the website; handling contact-form messages; basic technical logging. Never for marketing, profiling, or training AI models.
3. Categories of data — name, email, phone, message content from contact-form visitors, plus general technical data such as IP address.
4. Processor's obligations — processes data only on documented instructions, ensures confidentiality, applies appropriate security measures including HTTPS/TLS and restricted access.
5. Sub-processors — Controller authorises: Lovable (hosting/development) and Processor's payment provider. Processor informs Controller of any change.
6. Data breach notification — Processor notifies Controller within 48 hours of becoming aware of a breach.
7. Assistance with data subject rights — reasonable assistance responding to GDPR rights requests.
8. Duration, termination, return of data — on termination, Processor deletes all personal data unless legally required to retain it.
9. Audit — Controller may request evidence of compliance, with 10 business days' notice, once a year.
10. Liability — subject to the same limitations as the Terms of Service (§20).
Want a signed, standalone copy for your own records? Email kleineprinss@gmail.com.