Data Processing Agreement

Outline — placeholder, not final.

Draft — not final. This page is a working outline, not reviewed or approved by an attorney. It is not a binding legal agreement yet and should not be relied on as one.

For a business customer (a builder) whose own homeowner clients' personal data flows through Hearthline. Not yet applicable to Hurley House Co.'s own current use — this becomes relevant once Hearthline is sold to another builder.

Roles

The Customer (builder) acts as the Controller of its homeowner clients' personal data; Hearthline acts as the Processor.

Scope

  • Subject matter, duration, nature & purpose of processing
  • Categories of data subjects: the Customer's staff and its homeowner clients

Subprocessors

Same list as the Privacy Policy (Supabase, Vercel, Resend, Anthropic), plus a process for approving any new one.

Security & incident response

  • Security measures (reference the Privacy Policy's Security section)
  • Data subject request assistance
  • Breach notification timeline

On termination

Data return or deletion, and limited audit rights.