Data Processing Agreement
GDPR-compliant data processing terms for Enterprise customers and data protection compliance
Enterprise Customers
This DPA is automatically incorporated into your Enterprise agreement. Professional plan customers can request DPA coverage by contacting our legal team.
GDPR Compliant
Full compliance with EU General Data Protection Regulation
Standard Contractual Clauses
EU-approved clauses for international data transfers
Sub-processor Transparency
Full disclosure of all data processing partners
Agreement Overview
This Data Processing Agreement ("DPA") forms part of the PersonaLift Service Agreement between PersonaLift Inc. ("PersonaLift," "Processor") and the Customer ("Controller") regarding the processing of Personal Data in accordance with applicable Data Protection Laws.
Key Terms
Controller
The Customer who determines the purposes and means of processing Personal Data
Processor
PersonaLift, who processes Personal Data on behalf of the Controller
Personal Data
Any data relating to website visitors processed through our personalization service
Data Protection Laws
GDPR, CCPA, and other applicable data protection regulations
1. Processing Details
| Element | Details |
|---|---|
| Purpose | AI-powered website personalization and conversion optimization |
| Categories of Personal Data | Behavioral data, device information, location data (anonymized), session identifiers |
| Data Subjects | Website visitors of Controller's properties |
| Retention Period | 26 months maximum, or as instructed by Controller |
| Processing Operations | Collection, analysis, storage, automated decision-making, deletion |
2. Processor Obligations
Process Personal Data only on documented instructions from the Controller
Ensure confidentiality of processing through appropriate technical and organizational measures
Implement appropriate security measures including encryption and access controls
Only engage sub-processors with Controller approval and equivalent protection
Assist Controller in responding to data subject requests within 30 days
Notify Controller of any data breaches within 24 hours of discovery
Conduct Data Protection Impact Assessments when required
Delete or return Personal Data upon termination of services
3. International Data Transfers
PersonaLift may transfer Personal Data to countries outside the EEA for processing. All transfers are protected by appropriate safeguards:
Transfer Mechanisms
- • Standard Contractual Clauses (EU Commission approved)
- • Adequacy decisions for certain countries
- • Additional contractual safeguards where required
4. Security Measures
Technical Safeguards
- • Encryption in transit (TLS 1.3)
- • Encryption at rest (AES-256)
- • Multi-factor authentication
- • Regular security audits
- • Automated backup systems
Organizational Measures
- • Role-based access controls
- • Employee background checks
- • Data protection training
- • Incident response procedures
- • Regular compliance audits
5. Sub-processors
PersonaLift engages the following categories of sub-processors. A complete and current list is available on our Sub-processors page.
Cloud Infrastructure
AWS, Google Cloud Platform - for hosting and data storage
Analytics
Google Analytics, Mixpanel - for usage analytics and performance monitoring
Support Services
Zendesk, Intercom - for customer support and communication
Sub-processor Changes
We will provide 30 days notice of any new sub-processors. Customers may object to new sub-processors and terminate services if no suitable alternative can be found.
6. Data Subject Rights
PersonaLift will assist Controllers in responding to data subject requests, including:
Individual Rights
- • Right of access
- • Right of rectification
- • Right to erasure
- • Right to restrict processing
Additional Rights
- • Right to data portability
- • Right to object to processing
- • Rights related to automated decision-making
- • Right to withdraw consent
Response Timeframes
PersonaLift will provide assistance within 30 days of receiving a data subject request from the Controller. Emergency requests (e.g., data breaches) will be handled within 24 hours.
7. Contact Information
Data Protection Officer
Email: dpo@personalift.io
Address: PersonaLift Inc.
548 Market Street, Suite 35410
San Francisco, CA 94104
Legal & Compliance
Email: legal@personalift.io
Phone: +1 (415) 555-0847
Emergency: Available 24/7 for data breaches
This Data Processing Agreement is effective as of January 2025 and governs the processing of Personal Data by PersonaLift Inc. on behalf of its customers in accordance with applicable Data Protection Laws.
Last updated: January 2025 | Version 2.1