Data Processing Agreement
This agreement forms part of the Terms of Service between Callum Jones, trading as Solar Mailshot ("we", the processor) and you (the controller). It applies whenever we process personal data on your behalf, and meets the requirements of Article 28 of the UK GDPR.
1. When we act for you
We process personal data for you when:
- you upload your own list of names and addresses (Mail Your Own List); and
- homeowners send you an enquiry through a personal web page linked from your letters.
For letters sent through Targeted Mailshot and Tell the Neighbours, we select the homes using our own data and act as a controller of that data, not as your processor. You become a controller of any personal data a homeowner then gives you directly.
2. Details of the processing
- Subject matter and purpose: preparing, printing and posting your letters, checking the roofs at the addresses you supply, and passing on homeowner enquiries.
- Types of data: names, postal addresses, and any contact details and messages a homeowner sends in an enquiry.
- People concerned: the homeowners on your lists and homeowners who contact you.
- Duration: for as long as needed for each mailing. Uploaded lists and their roof data are deleted 30 days after you approve the mailing; we keep only a record of what happened to each home. Enquiries are kept while your account is open, unless you delete them sooner.
3. Our commitments
- We process the data only on your documented instructions, which are given by how you use the service.
- Everyone who handles the data is bound by confidentiality.
- We keep the data secure with appropriate technical and organisational measures, including encryption in transit, access controls and limited retention.
- We help you respond to requests from individuals and to meet your own security and data protection duties.
- We tell you without undue delay after becoming aware of a personal data breach affecting your data.
- At the end of the service we delete the data, unless the law requires us to keep it.
- We make available the information needed to show we meet these terms and allow reasonable audits, on reasonable notice.
4. Sub-processors
You authorise us to use these sub-processors: Contabo (hosting, on servers in the UK), Stannp (printing and posting), Google (geocoding and roof data for uploaded addresses), Anthropic (writing personalised letter text), Mapbox (maps), Resend (sending enquiry emails) and Twilio (sending enquiry text messages). We will give you notice of any new sub-processor so you can object, and we stay responsible for them. Some of these providers are based in the United States or use servers outside the UK. Where personal data leaves the UK we rely on the UK's adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework, where the provider is certified) or the UK International Data Transfer Addendum.
5. Your commitments
You confirm you have a lawful basis to send marketing to every person on any list you upload, that the list does not include anyone who has asked you not to contact them, and, where the list includes people's names, that you have screened it against the Mailing Preference Service (MPS) within the last 28 days. You will not upload special category data.
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