Splash Office Data Processing Addendum

Incorporation, scope and priority

This Data Processing Addendum forms part of the identified Company Agreement between Company and Splash Office LLC. Company Personal Data means personal information processed by Splash on Company’s behalf in providing the Service. This Addendum applies for as long as Splash processes that information, including justified retention after termination.

Within the adopted agreement package, this Addendum controls conflicting provisions concerning Company Personal Data. Separately executed agreements retain the priority stated in the Company Terms, subject always to nonwaivable law. Neither commercial instructions nor a limitation of liability authorizes processing prohibited by law. The existing contractual liability allocation is unchanged.

Roles and lawful instructions

Company determines the purposes of its customer service, employment and operational records. Splash acts as its processor or service provider for those activities, using the terminology applicable law requires. Where Company itself processes information for another party, it must have authority to appoint Splash for the permitted processing.

Splash separately determines purposes for its own business relationship, public website and inquiries and for genuinely independent service protection activities. A security or account label does not automatically turn Company directed processing into Splash’s independent processing. Actual purpose and conduct determine the role. Splash must not use this distinction to repurpose Company content.

Company instructs Splash through this agreement, selected features, configured permissions and other documented lawful instructions. Splash must inform Company if it considers an instruction unlawful and seek clarification. Processing required by law must be limited to that requirement, with advance notice where lawful. Each party remains responsible for its own statutory duties.

Processing schedule

Affected people include Company’s customers, prospects, contacts, staff, contractors, signers and communication participants. Information includes names and contact details; service addresses and equipment information; schedules, work and time records; precise work location and visit evidence; notes, photos and attachments; communications and assistant inputs and outputs; contracts and signing evidence; invoices and payment references; and relevant account, access and audit information.

Authorized operations include collection, organization, storage, retrieval, use, transmission, correction, support, export and deletion for scheduling, routing, service documentation, quoting, contracting, billing, lawful communications, connected services and configured assistant functions. Access to precise location and communications is limited to these purposes. The duration is the service relationship and the applicable retention schedule. This schedule neither enables a feature nor independently authorizes a message, payment or monitoring activity.

Processing restrictions and accountability

Splash will process Company Personal Data only for the specified purposes and documented lawful instructions. It will not sell that information, share it for cross context behavioral advertising, use it outside the direct business relationship or combine it with personal information from other sources except as expressly permitted by applicable law. The limited service license does not authorize general purpose model training or unrelated advertising.

Splash will provide the level of protection required by applicable law, notify Company promptly if it can no longer comply, and permit reasonable steps to stop and remedy unauthorized processing. Splash certifies that it understands and will comply with these restrictions. Where California service provider or contractor requirements apply, these restrictions and the assistance and oversight provisions must be interpreted to satisfy those requirements, without reducing protection required elsewhere.

Personnel and safeguards schedule

Splash must limit access to personnel who need it for authorized purposes and bind them to appropriate confidentiality obligations. Splash will maintain reasonable technical and organizational safeguards proportionate to the information, processing and risks.

The disclosed baseline includes encryption of network transport, encrypted storage of connected account credentials and access limited by company roles. These safeguards do not represent that every database is encrypted at rest or that Splash holds a particular audit certification. No country of processing or provider certification is promised by this schedule.

Operational procedures must address authorized access and revocation, incident handling, recovery access, lawful deletion and restoration restrictions. Company may request information sufficient to assess the measures actually used and material exceptions. Splash must not describe an unimplemented procedure or unverified vendor assurance as an existing control.

Individual rights and Company assistance

Splash will provide reasonable assistance, taking account of the nature of processing and information available to it, so Company can respond to applicable access, correction, deletion, portability, restriction, objection and appeal requests within legal deadlines. A request concerning Company controlled records will be referred to Company unless law requires Splash to respond directly. Identity and authority must be verified proportionately without collecting unnecessary information.

Splash will assist with applicable security, breach notification, data protection assessment, audit and automated decision making obligations. Company must give sufficient instructions and information for the assistance. Neither party may use this allocation to ignore a legal duty imposed directly on it. This Addendum does not assert that every right applies to every person or activity.

Compliance information and assessments

Splash will make relevant information available to demonstrate compliance and cooperate with reasonable assessments by Company or its qualified independent assessor. An existing independent assessment may meet overlapping requests only to the extent it covers the relevant controls and requirements. These provisions do not represent that such a report currently exists.

Assessments must protect other customers’ information, confidentiality and service security. Reasonable scheduling and scope safeguards must not prevent meaningful statutory oversight, investigation of a material concern or urgent remediation. Company may take reasonable and appropriate steps to ensure authorized use and stop and remedy unauthorized processing.

Subprocessors and independent providers

Splash must identify delegated providers, their functions and relevant processing information in the subprocessor schedule supplied to Company. Company authorizes only the identified processing under the agreement. Before a new or replacement subprocessor receives Company Personal Data, Splash will give advance notice and a meaningful opportunity to object on reasonable data protection grounds. The parties will work in good faith to resolve an objection or arrange a lawful alternative before the disputed processing begins.

Splash must enter written agreements imposing obligations consistent with this Addendum and remains accountable for delegated processing as applicable law requires. A proposed processing arrangement that cannot satisfy these requirements must not be activated under this authorization. Existing contractual and statutory remedies remain available if the issue cannot be resolved.

A provider independently selected and controlled by Company, including a connected payment or mailbox service, may have separate responsibilities. Splash must distinguish that role from processing it delegates, rather than classify every integration in the same way. Provider retention, training, transfer and deletion claims require the relevant verified agreement and configuration.

Security incidents

Splash will notify Company without undue delay after becoming aware of a security incident compromising Company Personal Data, and sooner where applicable law requires. Initial notice must not wait for completion of the investigation. Splash will provide available information about affected data and people, timing, likely effects, containment and a response contact, and supplement material findings as they become available.

Splash will take reasonable steps to contain and investigate the incident, preserve relevant evidence and assist Company with legally required notifications and remediation. Each party retains its own statutory notification duties. Notification does not by itself admit liability.

Retention, return and deletion schedule

After termination, Company has thirty days to obtain its data through the available database export and any recovery copies already configured, or through secure delivery arranged with Splash. After that export period, Splash will delete Company Personal Data from active systems, subject to documented legal retention requirements, including applicable requirements for executed agreements and payment records. A signed document is not exempt from deletion merely because it is signed. Splash will restrict retained records to their justified purpose and remove them when that basis ends, unless another lawful requirement applies. Data will not be retained indefinitely merely because Company might return.

The ordinary offsite recovery policy retains the seven newest verified daily bundles and four older weekly selections. This is a count based policy, not a guaranteed time to expiry. Failed or interrupted backup runs can leave older copies in place. Account closure requires explicit manual removal of nonexempt Splash controlled recovery copies rather than reliance on future backup runs. Recovery copies retained for a documented legal requirement must remain restricted to that purpose. Before restored data returns to ordinary use, applicable completed deletions and closure restrictions must be reapplied.

The current database export does not by itself establish that every attachment, photograph, executed PDF or signing evidence file has been included. Splash and Company must identify and arrange the necessary additional files during the export period. Company is responsible for its downloaded exports and copies held in its own connected accounts. Splash does not promise to erase copies outside its control. These provisions do not shorten an existing contractual export or deletion obligation.

During active service, detailed staff location trails retain full detail for thirty shop days, then five minute samples until 365 days. Arrival and departure pins saved with visits are separate business records and follow their justified work record purposes. The trail schedule does not delete every record containing a location.

Outbox bodies, HTML and attachment bytes generally clear after 365 days, while metadata remains for 1,825 days. Pending and failed items retain their bodies until the five year deletion because they remain available for retry. These rules concern outbox copies, not every separately stored message or attachment. Sessions expire from the registry after fifteen inactive days. Replay receipts and content security policy reports generally retain ninety days. Completed or discarded drafts retain thirty days.

Many customer, financial, audit, legal and work records do not have automatic expiry under the current category jobs. This is not permission for indefinite retention. Company and Splash must identify necessary purposes and applicable preservation requirements, carry out lawful deletion instructions and apply account closure obligations. Routine category periods do not override an earlier applicable deletion requirement.

Splash must keep proportionate evidence of closure actions, delegated deletion requests, recovery cleanup and justified exceptions. A legal hold must identify its basis, scope, owner and review need. Copies under a hold remain restricted, and Splash’s own contract and billing evidence must follow documented necessary purposes and applicable legal requirements.