This Data Processing Addendum ("DPA") applies when ChoicePilot processes personal data on behalf of a customer acting as controller.
1. Roles
- Customer is controller (or business) for customer personal data.
- ChoicePilot is processor (or service provider) for customer personal data.
2. Processing Details
- Subject matter: operation of ChoicePilot automation and execution workflows.
- Duration: for the term of services, unless extended by legal retention duties.
- Nature/purpose: ingesting connected system signals, generating recommendations, executing approved workflows, and providing support/security operations.
- Data categories: account identifiers, contact metadata, workflow context, communications metadata, business records linked by customer integrations.
- Data subjects: customer personnel, contacts, prospects, and end users represented in connected systems.
3. Processor Obligations
ChoicePilot will:
- process data only on documented instructions
- apply confidentiality and security controls
- assist with data subject requests where required
- assist with security incident response and regulatory cooperation
- delete or return customer data at termination, subject to lawful retention duties
4. Subprocessors
ChoicePilot may use subprocessors for hosting, storage, observability, and support operations under written obligations materially consistent with this DPA.
5. International Transfers
Where required, cross-border transfers are supported by appropriate contractual safeguards.
6. Security Incidents
ChoicePilot will notify customer without undue delay after confirming a security incident impacting customer personal data.
7. Audit and Information Rights
ChoicePilot will provide reasonable compliance information and documentation relevant to processor obligations, subject to confidentiality and security constraints.
8. Conflict
If this DPA conflicts with other service terms regarding personal data processing, this DPA controls for those matters.
9. Contact
Data protection inquiries: privacy@choicepilot.online