Data Processing Addendum
This addendum forms part of the agreement between the customer (“Controller”) and Cordello (“Processor”) for the Cordello service. It is written to be read, and to be redlined by your counsel.
1. Scope and roles
The Controller determines the purposes and means of processing the personal data it captures with the service (names, titles, companies, work emails, notes, and engagement data of trade-show contacts, and the accounts of its own staff). Cordello processes that data only on the Controller’s documented instructions, which are the service’s features as configured by the Controller.
2. Duration
Processing lasts for the term of the agreement. Within 30 days of termination Cordello deletes the Controller’s data from production systems; backups age out within 35 days thereafter. The Controller may export all of its data at any time before termination.
3. Confidentiality
Cordello ensures that persons authorized to process the data are bound by confidentiality obligations. Cordello staff cannot read a Controller’s lead book through the service; operational visibility is limited to counts and timestamps, and every staff action is logged.
4. Security measures
Encryption in transit (TLS 1.2+) and at rest; per-workspace logical isolation; role-based access with one-click deactivation; signed session cookies; encrypted storage of any third-party tokens (AES-256-GCM, key held outside the database); an immutable workspace audit trail; and the measures described on the Security page, which forms part of this addendum.
5. Sub-processors
Cordello uses the sub-processors listed on the Security page (currently Microsoft Azure; Microsoft Graph and Google Workspace where a rep connects a mailbox; HubSpot or Salesforce where the Controller connects one; Stripe for billing). Cordello gives at least 30 days’ notice of a new sub-processor by updating that page and emailing workspace owners; the Controller may object in writing, and if the objection cannot be resolved, terminate the affected service without penalty.
6. Assistance
Cordello assists the Controller in responding to data-subject requests. The service provides self-serve tools for access (workspace and lead export) and erasure (per-lead deletion); requests that cannot be met with those tools will be handled within 10 business days.
7. Personal-data breach
Cordello notifies the Controller’s workspace owners without undue delay, and in any case within 72 hours, after becoming aware of a personal-data breach affecting the Controller’s data, with the information reasonably available to allow the Controller to meet its own obligations.
8. Audit
On written request, no more than once a year unless required by a supervisory authority, Cordello makes available the information necessary to demonstrate compliance with this addendum, including third-party audit reports as they become available.
9. International transfers
Data is hosted in the United States. Where the Controller is established in the EEA, UK or Switzerland, the parties incorporate the Standard Contractual Clauses (Module Two) and the UK Addendum by reference; the Security page records the transfer measures.
10. Return and deletion
On termination the Controller may export its data; Cordello then deletes it as described in section 2 and certifies deletion on request.
Questions or a signable copy: privacy@cordello.app.