Data Processing Agreement - Holiday Home Concierge

IMPORTANT POINTS (Summary)

This agreement governs how we process personal data on your behalf
You (the Host) are the Data Controller; we are the Data Processor
We process data only according to your instructions and this agreement
We maintain appropriate security measures to protect personal data

1. Introduction

This Data Processing Agreement (“DPA”) forms part of the Terms & Conditions between New Logic Ltd (“Processor”, “we”, “us”) and you (“Controller”, “Host”) for the provision of Holiday Home Concierge services.

This DPA sets out the terms on which we process personal data on your behalf in accordance with UK GDPR.

2. Definitions

“Personal Data” has the meaning given in UK GDPR
“Processing” has the meaning given in UK GDPR
“Data Subject” means the individual whose personal data is processed
“Sub-processor” means any third party engaged by us to process personal data

3. Roles and Responsibilities

3.1 Controller Responsibilities

As the Controller, you are responsible for:

Ensuring you have a lawful basis for processing
Providing necessary notices to data subjects
Responding to data subject requests
Ensuring data accuracy

3.2 Processor Responsibilities

As the Processor, we will:

Process personal data only on your documented instructions
Ensure personnel are bound by confidentiality obligations
Implement appropriate security measures
Assist you in responding to data subject requests
Delete or return personal data upon termination

4. Processing Details

4.1 Subject Matter

Processing of personal data to provide Holiday Home Concierge services, including property management, guest services, and AI-powered content generation.

4.2 Duration

For the duration of the service agreement plus any legally required retention period.

4.3 Categories of Data Subjects

Property hosts and their staff
Property guests
End users of Alexa-enabled services

4.4 Types of Personal Data

Contact information (names, emails, phone numbers)
Property information
Booking and stay information
Usage data
Voice interaction metadata (not recordings)

5. Security Measures

We implement appropriate technical and organizational measures including:

Encryption of data in transit and at rest
Access controls and authentication
Regular security testing
Incident response procedures
Staff training

6. Sub-processors

6.1 Current Sub-processors

We use the following sub-processors:

6.2 Changes to Sub-processors

We will notify you of any intended changes to sub-processors, giving you the opportunity to object.

7. Data Subject Rights

We will assist you in responding to data subject requests including:

Access requests
Rectification requests
Erasure requests
Portability requests

8. Data Breach Notification

In the event of a personal data breach, we will:

Notify you without undue delay (within 72 hours where feasible)
Provide information about the nature and impact of the breach
Assist with your notification obligations

9. Audits

You may audit our compliance with this DPA, subject to reasonable notice and confidentiality obligations.

10. International Transfers

You agree to indemnify and hold harmless New Logic Ltd from any claims arising from your use of the Service or breach of these Terms.

11. Termination

Upon termination of services:

We will delete or return all personal data
Deletion will be completed within 90 days
We may retain data where required by law

12. Liability

Liability under this DPA is subject to the limitations in the main Terms & Conditions.

13. Contact Us

For DPA-related queries:

Email: legal@holidayhomeconcierge.com