Template. Replace the bracketed details and have a solicitor review before launch.
Data processing agreement
Last updated [date]. Part of the Terms of service for venues.
Roles
The venue is the controller of its customers' personal data. [Company legal name] is the processor and processes that data only on the venue's documented instructions, which are these terms and the venue's use of the admin panel.
Details of processing
| Subject matter | Running digital stamp cards for the venue |
|---|---|
| Duration | The subscription (or free trial), plus 30 days after cancellation, or 90 days after a trial ends without a plan, for deletion. Cards with no activity for 24 months are deleted during the subscription. |
| Data subjects | The venue's customers who join its stamp card |
| Personal data | First name, optional email, card number, stamp and reward history, marketing consent and opt-outs, Wallet device identifiers and push tokens, card cookie, a browser counter for the Add to Wallet button (functional, no tracking) |
| Special category data | None |
Our commitments
- People with access to the data are bound by confidentiality.
- Security measures: encryption in transit (TLS) and at rest, hashed device keys and passwords, access limited by role, audit logs of stamps and corrections, backups and monitoring.
- We tell the venue without undue delay, and within 48 hours, after becoming aware of a personal data breach affecting its data.
- We help the venue answer customer requests (access, correction, deletion). Customers can also delete their own card, or stop offers, from their card page, and the venue can record an opt-out in the admin panel.
- On termination we delete the venue's customer data 30 days after cancellation, after offering an export, unless the law requires us to keep it.
- We make information available to show compliance and allow reasonable audits once a year on 30 days' notice.
Sub-processors
The venue authorises these sub-processors. We give 30 days' notice of changes, and the venue may object.
- Microsoft Azure: hosting and database, [region]
- [Email provider]: transactional emails
- Apple and Google: Wallet pass delivery and updates
- Stripe: billing of the venue (no customer data)
International transfers
Where personal data is transferred outside the UK, EEA or Australia, including support access from Pakistan, the parties rely on the EU Standard Contractual Clauses (module 2 or 3) and the UK International Data Transfer Addendum, which are incorporated by reference.