Data Processing Agreement (DPA)

1. Roles

• Data Controller: You (The Customer).
• Data Processor: TrueDemand Holmes.
• Sub-processor: Third-party services engaged by us (e.g., cloud hosts, AI APIs).

2. Scope and Nature of Processing

TrueDemand Holmes will only process personal data strictly in accordance with your documented instructions. Data will be processed for the duration of your active subscription.

3. Authorized Sub-processors

You grant general authorization for us to engage Sub-processors, specifically including Cloud Infrastructure Providers and Artificial Intelligence Partners (e.g., Google Gemini, DeepSeek).

4. Security and Confidentiality

TrueDemand Holmes implements robust technical and organizational measures to protect your data, including industry-standard encryption protocols.

5. Personal Data Breaches

In the event of a confirmed security breach, TrueDemand Holmes will notify you without undue delay (no later than 48 hours).

6. International Data Transfers

When transferring data out of regions with strict privacy frameworks, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs).