Draft, not legal advice. This is placeholder copy to unblock launch prep. Have a qualified lawyer review it against your actual data flows, jurisdictions, and standard-contractual-clause requirements before offering it to real customers.

Data Processing Agreement

Last updated: 22 September 2026

1. Who this is for

Your agency ("Customer", the data controller) enters candidate and client personal data into Deskspark. Deskspark ("we", the data processor) processes that data only on Customer's instructions, to provide the Deskspark service. This agreement sets out how we do that. It supplements the Terms of Service and Privacy Policy, and applies automatically once a workspace is created.

2. What we process

Candidate and client contact details, employment history, notes, interview outcomes, and any other personal data Customer chooses to store in Deskspark: exactly the data described in the Privacy Policy's "What we collect" section, nothing beyond it.

3. Sub-processors

We use the following sub-processors to run Deskspark: Vercel (application hosting), Supabase (database, authentication, file storage), Anthropic and ElevenLabs (AI text and voice generation for the Vicki assistant), Resend (email delivery for broadcast campaigns), and Mapbox (address geocoding for non-UK locations and radius search: UK postcodes are geocoded via the UK government's own postcodes.io service instead). Data is currently hosted in the United States (AWS us-east-1, via Vercel and Supabase). We'll give reasonable notice before adding a new sub-processor that would materially change this.

4. International transfers

Where Customer or the individuals in its pipeline are in the EU and data is processed in the US, the transfer is safeguarded by the EU Standard Contractual Clauses (Module Two: Controller to Processor). Where Customer or the individuals in its pipeline are in the UK, the transfer is instead safeguarded by the UK International Data Transfer Addendum to the EU SCCs, issued by the UK Information Commissioner's Office. [Annexes: description of transfer, technical and organizational security measures, sub-processor list, competent supervisory authority, to be attached once counsel has finalized our registered legal entity and address].

5. Security

Data is encrypted in transit and at rest, access is scoped per-workspace via row-level security so one customer's data is never visible to another, and access to production data is limited to what's needed to operate the service.

6. Sub-processor changes and audits

Customer may request reasonable information to verify our compliance with this agreement. On termination, Customer's data can be exported in full at any time (Settings → Export All Data). Any individual record an Admin permanently deletes (Trash → Delete Forever) is removed from active systems immediately, along with every directly linked record (call logs, notes, attachments, hotlist and shortlist entries); anything left in Trash is automatically purged within 90 days by a daily background job. Email correspondence, the internal activity feed, and the security audit log are retained as legitimate business records rather than deleted alongside a purged individual, consistent with the Privacy Policy's retention terms.

7. Contact

Questions about this agreement, or to request a signed copy for your own records: privacy@deskspark.io.