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Data Processing Agreement (DPA)

Effective Date: June 21, 2025

This Data Processing Agreement ("Agreement") forms part of the Terms of Service between you ("Customer") and Thumper ("Processor") and applies when Thumper processes personal data on your behalf as part of providing services.

1. Definitions

  • "Data Controller" means the entity that determines the purposes and means of processing personal data.
  • "Data Processor" means the entity that processes personal data on behalf of the Data Controller.
  • "Personal Data" means any information relating to an identified or identifiable individual.

2. Scope and Purpose

The Processor will process Personal Data only as necessary to provide the Service and in accordance with the Customer’s documented instructions.

3. Sub-Processors

The Customer authorizes Thumper to use sub-processors for hosting, email delivery, and infrastructure. A list of sub-processors is available upon request. Thumper ensures sub-processors are bound by data protection obligations no less protective than this Agreement.

4. Security

The Processor will implement appropriate technical and organizational measures to protect Personal Data against unauthorized access, loss, or destruction.

5. Data Subject Rights

Processor will assist Customer in fulfilling its obligations to respond to data subject requests to access, rectify, or erase Personal Data, or to restrict or object to processing, as required by applicable law.

6. Data Breach Notification

In the event of a data breach involving Personal Data, the Processor will notify the Customer without undue delay and provide relevant information as it becomes available.

7. Data Transfers

Thumper may transfer Personal Data to countries outside the EEA or the UK as necessary, provided such transfers comply with applicable data protection laws and appropriate safeguards (such as Standard Contractual Clauses) are in place.

8. Deletion or Return of Data

Upon termination of the Service, the Processor will delete or return all Personal Data to the Customer, unless retention is required by law.

9. Audit Rights

Upon written request, the Customer may conduct a review of Thumper’s data processing practices and security measures, subject to confidentiality obligations and reasonable limits on frequency.

10. Contact

For questions regarding this Agreement, please contact us at:

  • 📧 [email protected]
  • 🌐 https://thumperuptime.com/contact

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