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Data Processing Agreement (DPA) to the Public Offer Agreement for Providing Access to the CRM System HomexCRM
1. General Provisions
1.1. This Data Processing Agreement (hereinafter — the “DPA”) forms an integral part of the Public Offer Agreement (hereinafter — the “Agreement”) and applies exclusively to the processing of personal data within the use of the HomexCRM CRM system.
1.2. This DPA governs the processing of personal data in accordance with Regulation (EU) 2016/679 (GDPR) and other applicable data protection laws.
1.3. Under this Agreement:
• The User acts as the Data Controller;
• HomexCRM acts as the Data Processor solely with respect to the data processed by the User within the CRM system.
2. Subject Matter of Data Processing
2.1. HomexCRM processes personal data exclusively based on the User’s instructions and solely for the purpose of providing CRM functionality.
2.2. Possible categories of data include:
• identification data (name, surname);
• contact data (email, phone number);
• User’s client data;
• transaction, property, and communication data;
• any other data voluntarily entered by the User into the system.
2.3. Categories of data subjects include:
• the User’s clients;
• the User’s employees;
• counterparties;
• any other individuals whose data is entered into the system by the User.
3. Roles and Scope of Responsibility
3.1. HomexCRM does not determine the purposes or means of processing personal data and acts solely as a data processor.
3.2. The User is solely responsible for:
• the lawfulness of data collection;
• the existence of legal grounds for processing;
• instructions regarding the use of the CRM system;
• the content of data uploaded into the system.
4. Obligations of HomexCRM (Data Processor)
HomexCRM undertakes to:
4.1. Process personal data only in accordance with the User’s instructions.
4.2. Ensure the confidentiality of personal data.
4.3. Implement appropriate technical and organizational security measures, including:
• data encryption (where applicable);
• access control;
• data backups;
• protection against unauthorized access.
4.4. Ensure access to data only for authorized personnel.
4.5. Notify the User of any security incidents without undue delay.
4.6. Provide reasonable assistance to the User in fulfilling GDPR obligations.
5. Sub-processors
5.1. The User agrees that HomexCRM may engage sub-processors (hosting providers, data centers, infrastructure services).
5.2. All sub-processors are required to ensure an adequate level of data protection in accordance with GDPR.
5.3. HomexCRM may use infrastructure located in the United States of America (USA) and other jurisdictions with appropriate data protection safeguards.
6. International Data Transfers
6.1. The User agrees that personal data may be transferred and stored outside the European Economic Area, including the USA.
6.2. Such transfers are carried out in compliance with GDPR and applicable safeguards, including:
• Standard Contractual Clauses (SCCs);
• other legally permitted transfer mechanisms.
7. Data Retention and Deletion
7.1. Data is processed for the duration of the Agreement.
7.2. Upon termination of the Agreement:
• data is retained for up to 30 calendar days;
• after that, it may be permanently deleted without the possibility of recovery.
7.3. The User has the right to export their data before deletion.
8. Data Subject Rights
HomexCRM assists the User in fulfilling data subject requests, including:
• access to data;
• rectification;
• erasure;
• restriction of processing;
• data portability.
9. Liability
9.1. Each party is responsible for its obligations under GDPR within its respective role.
9.2. HomexCRM shall not be liable for unlawful processing resulting from the User’s instructions or actions.
10. Final Provisions
10.1. This Agreement enters into force upon acceptance of the main Agreement.
10.2. In case of any conflict between this DPA and other provisions of the Agreement regarding data processing, this DPA shall prevail.
10.3. HomexCRM reserves the right to update this DPA in case of changes in legislation or service infrastructure.
11. Contact Information
For data protection inquiries:
Email: homexcrm.official@gmail.com