Data Processing Agreement

1. Roles

The Controller decides why and how end users' personal data is processed. Chatslane processes it only on the Controller's documented instructions, which are the Terms, this DPA and the Controller's use of the service.

2. Subject matter and duration

Providing the Chatslane in-app support chat and inbox, for as long as the Controller uses the service, plus the deletion period below.

3. Categories of data subjects and data

Data subjects: end users of the Controller's apps who use the chat, and the Controller's team members.

Categories of personal data:

• Messages that end users send and receive in the in-app chat
• Photos and screenshots end users attach to messages
• An end-user identifier chosen by the developer's app (its own user ID, or a random ID stored on the device)
• Device platform (iOS, Android or web) and when the user was last active in the chat
• Name and email address, only if the developer's app passes them in or the user enters their email in the chat to get replies by email
• Other context the developer's app chooses to send, such as app version, device model, OS version, locale or plan
• Records of App Store review requests sent from the inbox and whether the app showed the prompt
• Offer cards sent in chat, whether the user tapped them, and purchase details (product, amount, currency) if the developer's app reports a purchase

4. Processor obligations

• Process personal data only on documented instructions
• Make sure staff with access are bound by confidentiality
• Implement appropriate technical and organisational security measures (encryption in transit, role-based access, per-customer isolation with row-level security, access logging)
• Help the Controller respond to data subject requests and with data protection impact assessments where reasonable
• Notify the Controller without undue delay after becoming aware of a personal data breach
• Make available information needed to show compliance with this DPA

5. Subprocessors

The Controller authorises the subprocessors listed below. Chatslane will give notice of new subprocessors at least 30 days in advance, during which the Controller may object. Chatslane imposes data protection terms on each subprocessor that are at least as protective as this DPA.

6. International transfers

Where personal data is transferred outside the EEA/UK, Chatslane relies on appropriate safeguards such as the EU Standard Contractual Clauses. TODO(legal): confirm transfer mechanism per subprocessor.

7. Deletion and return

The Controller can export or permanently delete an individual end user's data from the inbox at any time; that deletion takes effect immediately in the live database. When the Controller deletes data or closes their account, Chatslane deletes the personal data within [30] days, apart from backups that expire on a rolling basis, unless the law requires keeping it. The Controller can export data before closing the account.

8. Liability and law

Liability under this DPA is subject to the limits in the Terms. This DPA is governed by the laws of [JURISDICTION]. [COMPANY NAME], [REGISTERED ADDRESS]. Contact: info@chatslane.com.