Data Processing Agreement

Effective Date: May 5, 2025

This Data Processing Agreement (“DPA”) is an integral part of the agreement between BluChip and the customer (“Customer” or “you”) and is subject to the terms of that Agreement.

Definitions

  • Agreement: Refers to this data processing agreement and any associated schedules.
  • Controller: The entity that determines the purposes and means of processing personal data, as defined under applicable data protection laws.
  • Processor: BluChip, responsible for processing personal data on behalf of the Customer, as defined in the applicable data protection laws.
  • Personal Data: Data that relates to an identified or identifiable individual.
  • Data Subject: An individual whose personal data is processed.
  • Subprocessor: Third parties that BluChip engages to process personal data on behalf of the Customer.
  • Relevant Personal Data: The categories of personal data processed under this Agreement.

1. Obligations of BluChip

  • 1.1 Compliance: BluChip agrees to comply with applicable data protection laws in processing personal data.
  • 1.2 Security Measures: BluChip will implement appropriate technical and organizational measures to protect personal data from unauthorized access, alteration, destruction, or disclosure.
  • 1.3 Processing Instructions: BluChip will only process personal data based on Customer’s documented instructions and as necessary to perform its obligations under this Agreement.
  • 1.4 Confidentiality: BluChip ensures that its personnel and Subprocessors are bound by confidentiality obligations regarding personal data.
  • 1.5 Subprocessors: BluChip will only engage Subprocessors with prior written approval from the Customer and will ensure that Subprocessors comply with the same data protection obligations.
  • 1.6 Security Incidents: BluChip will promptly notify the Customer of any personal data breaches or security incidents.
  • 1.7 Data Subject Rights: BluChip will assist the Customer in responding to data subject requests related to the exercise of their rights under applicable data protection laws.

2. Data Processing Details

  • 2.1 Processing Activities: BluChip processes personal data for the purpose of providing its services to the Customer, such as automating networking tasks and communication through LinkedIn and Gmail.
  • 2.2 Duration of Processing: Personal data will be processed for the duration of the Agreement and any additional periods as necessary under applicable law.
  • 2.3 Data Subjects: Personal data may pertain to Customer’s employees, affiliates, service providers, clients, and users of Customer’s services.
  • 2.4 Categories of Personal Data: The types of personal data processed may include contact details, login credentials, IP addresses, device and browser information, and metadata.
  • 2.5 Special Categories of Data: BluChip does not expect to process any sensitive personal data under this Agreement.

3. General Terms

  • 3.1 Termination: This Agreement is effective as of the date of execution and terminates upon the expiration or termination of the Services Agreement.
  • 3.2 Governing Law: This Agreement is governed by applicable laws and the exclusive jurisdiction of the courts.

4. Security Measures

  • 4.1 Cloud Infrastructure: BluChip operates its services using cloud infrastructure and takes appropriate security measures to protect data.
  • 4.2 Data Pseudonymization: Personal data is pseudonymized to ensure privacy, with any unnecessary attributes removed.
  • 4.3 Security & Compliance: BluChip maintains strong security measures, regularly updated systems, and compliance with relevant certifications.

5. Data Processing Operations

  • 5.1 Purpose: BluChip processes personal data to provide web services, including automation of networking tasks, communication with customers, and compliance with legal obligations.
  • 5.2 Data Transfer: BluChip may transfer personal data to its Subprocessors in accordance with the terms of this Agreement.

6. Contact and Enforcement

  • 6.1 Contact: For any queries related to data processing, customers should contact BluChip’s designated representatives for assistance.

This Agreement ensures that BluChip processes personal data responsibly, adhering to relevant data protection laws and regulations.

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