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Data Processing Agreement Overview

This Data Processing Agreement ("DPA") forms part of the Terms of Service between you ("Customer") and Growth ("Processor") and applies where and only where Growth processes Personal Data on behalf of Customer.

Definitions

• Controller: The entity that determines the purposes and means of processing Personal Data
• Processor: Growth, acting on behalf of and under instructions from the Controller
• Personal Data: Any information relating to an identified or identifiable natural person
• Processing: Any operation performed on Personal Data

Scope and Purpose

Growth processes Personal Data only:

• To provide the Services as described in the Terms of Service
• In accordance with Customer's documented instructions
• As required by applicable law

Data Subject Rights

Growth will assist Customer in fulfilling Data Subject requests, including:

• Access to Personal Data
• Rectification of inaccurate Personal Data
• Erasure of Personal Data
• Restriction of processing
• Data portability

Security Measures

Growth implements appropriate technical and organizational measures including:

• Encryption of Personal Data in transit and at rest
• Regular security assessments and audits
• Access controls and authentication procedures
• Employee training on data protection
• Incident response procedures

Sub-processors

Growth may engage sub-processors to assist in providing the Services. All sub-processors are bound by data protection obligations equivalent to those in this DPA.

Data Transfers

Growth ensures appropriate safeguards for international data transfers, including Standard Contractual Clauses and adequacy decisions where applicable.

Data Breach Notification

Growth will notify Customer of any Personal Data breach affecting Customer data within 72 hours of becoming aware of the breach.

Data Retention and Deletion

Growth will delete or return Personal Data to Customer upon termination of the Services, unless retention is required by law.

Contact Information

For DPA-related inquiries, contact our Data Protection Officer at: dpo@growth.com