This Data Processing Addendum (“DPA”) forms part of the agreement between
NewHomePage LLC (“Company”) and Customer.1. Roles of the Parties Where Customer uploads personal data into the Platform, Customer acts as Data Controller and NewHomePage acts as Data Processor or Service Provider. Where Company provides licensed data products, Company acts as an independent Business/Data Broker.
2. Scope of Processing Company processes Customer-uploaded data solely for the purpose of providing contracted services.
3. No Sale of Customer Data Company does not sell personal information contained in Customer-uploaded CRM data.
4. Confidentiality Personnel authorized to process Customer data are bound by confidentiality obligations.
5. Security Measures Company implements commercially reasonable administrative, technical, and physical safeguards to protect Customer data.
6. Subprocessors Company may engage subprocessors for hosting, analytics, or support. Company remains responsible for their compliance with this DPA.
7. Consumer Rights Assistance To the extent legally required, Company will provide reasonable assistance to Customer in responding to verified consumer rights requests relating to Customer-uploaded data.
8. Data Retention & Deletion Upon termination of services, Customer-uploaded data will be deleted or returned in accordance with the master agreement, unless retention is required by law.
9. Limitation This DPA applies only to Customer-uploaded personal data and does not apply to independently licensed data products sold by Company.