Data Processing

This addendum applies where TOTO-Flow processes personal data on behalf of a Customer under the Terms of Service. The Customer is the controller (or processor for its own clients) and TOTO-Flow is the processor. It supplements the Terms and is intended to meet Article 28 of the GDPR. A signed copy is available on request.

Subject matter and duration: delivery of the ordered services for the term of the agreement. Nature and purpose: receiving, storing, analysing, summarising and routing business data as instructed by the Customer. Data subjects: the Customer's staff, customers, suppliers, candidates and contacts. Data types: contact details, communications content, call recordings and transcripts, invoices and contract data, and other data the Customer chooses to connect.

Process personal data only on the Customer's documented instructions, including for international transfers, unless the law requires otherwise, in which case we will inform the Customer where permitted.

Ensure that people authorised to process the data are bound by confidentiality.

Apply the security measures described on our Security page.

Assist the Customer, taking account of the nature of processing, with data subject requests, security, breach notification, impact assessments and prior consultation.

Notify the Customer without undue delay after becoming aware of a personal data breach affecting its data.

Make available the information needed to demonstrate compliance and allow and contribute to reasonable audits, on reasonable notice and subject to confidentiality, no more than once a year unless required by a regulator or following a breach.

The Customer gives general authorisation for the use of sub-processors, such as hosting, email delivery and payment providers. We bind each to data protection terms no less protective than these, remain responsible for them, and will give at least 30 days' notice of new sub-processors so the Customer can object on reasonable data protection grounds. The current list is available on request.

Where processing involves a transfer outside the EEA, we rely on an adequacy decision, the European Commission's Standard Contractual Clauses (which are incorporated by reference where applicable), or another lawful mechanism.

On termination we make the Customer's data available for export for 30 days, then delete it from active systems within 60 days and from backups on their normal rotation, unless the law requires retention.

Liability under this addendum is subject to the limitations in the Terms of Service. If this addendum conflicts with the Terms on the processing of personal data, this addendum prevails.

Data protection enquiries: info@totoflow.us.