ملحق معالجة البيانات

This is a template provided for convenience and must be reviewed by qualified counsel before use.

This Data Processing Addendum (“DPA”) forms part of the Terms of Service or other written agreement (the “Agreement”) between MapDove, Inc., [address] (“MapDove”, “Processor”) and the customer identified in the Agreement (“Customer”, “Controller”). It applies where MapDove processes Customer Personal Data in providing the Services. Capitalized terms not defined here have the meaning given in the Agreement.

1. Definitions

• “Data Protection Laws” means all laws applicable to the processing of personal data under the Agreement, which may include the EU General Data Protection Regulation 2016/679 (“GDPR”), the UK GDPR and Data Protection Act 2018, the Swiss Federal Act on Data Protection, U.S. state privacy laws (such as the California Consumer Privacy Act as amended), and the UAE Federal Decree-Law No. 45 of 2021, each as applicable.
• “Customer Personal Data” means personal data that MapDove processes on behalf of Customer under the Agreement.
• “Sub-processor” means a third party engaged by MapDove to process Customer Personal Data.
• “Security Incident” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Customer Personal Data.
• “Controller”, “processor”, “data subject”, “personal data”, “processing” and “supervisory authority” have the meanings given in the GDPR; “business”, “service provider” and “sell”/“share” have the meanings given in applicable U.S. state laws.

2. Scope and roles

2.1 Customer is the controller (or business) and MapDove is the processor (or service provider) for Customer Personal Data.

2.2 MapDove is an independent controller for personal data it processes for its own purposes as described in the Privacy Policy — for example account administration, billing, security and fraud prevention — and this DPA does not apply to that processing.

2.3 Nature of the Services. The hosted MapDove analytics are built on a synthetic demo dataset that contains no personal data. Customer Personal Data is therefore expected to be limited to the categories in Annex 1, unless Customer and MapDove agree in an Order to process customer-supplied data feeds.

3. Processing instructions

3.1 MapDove will process Customer Personal Data only on Customer’s documented instructions, which are the Agreement, this DPA, Customer’s configuration and use of the Services, and any other written instructions agreed by the parties. MapDove will inform Customer if, in its opinion, an instruction infringes Data Protection Laws.

3.2 Customer is responsible for the lawfulness of its instructions and for having a lawful basis, and any notices and consents required, for the processing of Customer Personal Data.

3.3 Service-provider commitments. MapDove will not sell or share Customer Personal Data; retain, use or disclose it for any purpose other than performing the Services or as permitted by Data Protection Laws; or combine it with personal data received from other sources except as permitted by law.

4. Confidentiality

MapDove ensures that personnel authorized to process Customer Personal Data are bound by confidentiality obligations and receive appropriate data protection training, and that access is limited to those who need it.

5. Security

5.1 MapDove implements appropriate technical and organizational measures to protect Customer Personal Data, taking into account the state of the art, costs, and the nature, scope, context and purposes of processing. Current measures are described in Annex 2.

5.2 MapDove may update its measures, provided that updates do not materially decrease the overall level of protection.

6. Sub-processors

6.1 General authorization. Customer gives MapDove general authorization to engage Sub-processors. MapDove currently uses Sub-processors in the following categories:

A current list naming each Sub-processor is available on request to privacy@mapdove.com [or at: link].

6.2 Obligations. MapDove will impose on each Sub-processor data protection obligations no less protective than this DPA and remains responsible for its Sub-processors’ performance.

6.3 Changes. MapDove will notify Customer at least 30 days before authorizing a new Sub-processor (by email to the account owner or a subscription mechanism). Customer may object on reasonable data-protection grounds within that period. The parties will discuss the objection in good faith; if no resolution is reached, Customer may terminate the affected Services and receive a refund of prepaid fees for the remaining term.

7. Data subject requests

Taking into account the nature of processing, MapDove will assist Customer by appropriate technical and organizational measures in responding to requests from data subjects to exercise their rights. If MapDove receives a request directly, it will redirect the data subject to Customer where the request relates to Customer Personal Data, unless legally required to respond. Many requests can be handled by Customer directly in the Services (for example, editing or removing members).

8. Security Incidents

8.1 MapDove will notify Customer without undue delay, and in any event within 72 hours, after becoming aware of a Security Incident affecting Customer Personal Data.

8.2 The notification will describe, to the extent known, the nature of the incident, the categories and approximate number of data subjects and records concerned, likely consequences, and measures taken or proposed. MapDove will provide updates as information becomes available and take reasonable steps to contain and remediate the incident.

8.3 Notification is not an acknowledgment of fault or liability.

9. Assistance

MapDove will provide reasonable assistance to Customer with data protection impact assessments and prior consultations with supervisory authorities, to the extent required by Data Protection Laws and relating to the Services.

10. Audits

10.1 MapDove will make available information reasonably necessary to demonstrate compliance with this DPA, including summaries of [third-party audit reports or security assessments], and answers to reasonable security questionnaires, no more than once per year.

10.2 If this information is insufficient to demonstrate compliance, or where required by a supervisory authority, Customer may conduct an audit with at least 30 days’ notice, during business hours, subject to confidentiality and at Customer’s cost, in a manner that does not compromise the security of other customers.

11. International transfers

Where Customer Personal Data is transferred to a country that does not provide an adequate level of protection under Data Protection Laws, the parties agree that the applicable Standard Contractual Clauses (Module Two, controller to processor, and where applicable the UK Addendum or Swiss amendments) are incorporated by reference, with Annexes completed by Annex 1 and Annex 2 of this DPA. [Governing law and forum for the clauses: specify.] MapDove will ensure equivalent safeguards for onward transfers to Sub-processors.

12. Return and deletion

On termination of the Services, MapDove will, at Customer’s choice, return Customer Personal Data (by self-service export or on request within 30 days) and then delete it within [90] days, including from backups on their normal rotation, unless retention is required by law. MapDove will certify deletion on request.

13. Liability and precedence

Each party’s liability under this DPA is subject to the limitations in the Agreement. If this DPA conflicts with the Agreement regarding the processing of Customer Personal Data, this DPA prevails. The Standard Contractual Clauses, where applicable, prevail over both.

Annex 1 — Description of processing

Annex 2 — Technical and organizational measures

• Encryption of data in transit (TLS) and of storage volumes and backups at rest at the infrastructure level.
• Credential protection: passwords hashed with a modern, salted algorithm; API keys stored only as hashes and shown once at creation; session cookies HttpOnly, SameSite=Lax and Secure; sessions invalidated on password change.
• Access control: role-based access within organizations (owner, admin, member); API keys cannot manage keys, members or billing; least-privilege staff access, with two-factor authentication required for platform administrators; logged administrative actions.
• Account security: optional two-factor authentication for all users; throttling of repeated sign-in attempts.
• Logging and monitoring: audit log of security-relevant events (sign-ins, failures, key creation and revocation, plan and member changes, exports); error tracking and service monitoring.
• Tenant isolation: all customer records scoped to the organization at the application and query level.
• Resilience: regular backups, tested restoration, infrastructure redundancy as provided by the hosting provider.
• Secure development: code review, dependency updates, automated testing, separation of development and production environments.
• Vendor management: due diligence and written data protection terms with Sub-processors.
• Incident response: documented procedure, on-call responsibility and post-incident review.
• Data minimization: the analytics dataset is synthetic; no personal location data is collected or processed.

Contact

Privacy inquiries: privacy@mapdove.com · Legal notices: legal@mapdove.com · MapDove, Inc., [address]