Data Processing Addendum
Terms that apply where SnxwFairies processes personal data on a customer's behalf.
1. Roles
The customer is the Data Fiduciary and determines the purpose of processing. SnxwFairies is the Data Processor and processes personal data only on the customer's documented instructions.
2. Scope and duration
The subject matter, nature and purpose of processing, the categories of data principal, and the duration — which is the term of the agreement plus any agreed retention window.
3. Processor obligations
To process only on instruction; to keep personnel bound by confidentiality; to apply appropriate technical and organisational security measures; and to assist the customer in responding to data principal requests.
4. Sub-processors
The current list of sub-processors is available on request. The customer is notified before a new sub-processor is engaged, and each sub-processor is bound by obligations no less protective than this Addendum.
5. Security measures
Encryption of credentials at rest, no storage of one-time authentication codes in readable form, per-user access control with immediate revocation, tenant isolation enforced in code and verified by automated tests, and an append-only audit trail with secret redaction.
6. Personal data breach
The processor notifies the customer without undue delay after becoming aware of a personal data breach, with the information the customer needs to meet its own reporting duties, and co-operates with the customer's response to it.
7. Data principal requests
SnxwFairies provides the customer with the means to fulfil access and erasure requests directly within the service, and assists where a request cannot be fulfilled that way.
8. Return and deletion
The customer may ask for its data to be returned in a machine-readable format and for it to be deleted on termination, subject to any retention required by law. Both are carried out on request, because no self-service export and no automated deletion on termination is built yet.
9. Audit
The customer may request the information it reasonably needs to verify compliance with this Addendum, in a form and at a frequency agreed between the parties, and the processor answers in writing.
10. Liability and governing law
The liability cap in section 10 of the Terms of Service applies to this Addendum: the total liability of SnxwFairies arising out of or in connection with it is capped at the fees the customer paid in the 12 months before the event giving rise to the claim. This Addendum is governed by the laws of India, and the courts at Chhatrapati Sambhajinagar, Maharashtra have exclusive jurisdiction over any dispute arising out of or in connection with it.