This Data Processing Addendum ("DPA") forms part of the Terms of Service between the Operator ("Controller") and HamiltonDevCo ("Stowlane," "Processor") and governs Stowlane's processing of personal data about the Operator's storage tenants ("Tenant Personal Data") on the Operator's behalf.

1. Roles of the parties

The Operator is the Controller of Tenant Personal Data and determines the purposes and means of its processing. Stowlane is the Processor and processes Tenant Personal Data only on the Operator's documented instructions, which include these Terms, the Privacy Policy, and the Operator's use of the Service's features. Stowlane will inform the Operator if, in its opinion, an instruction violates applicable data-protection law.

2. Scope and nature of processing

3. Operator (Controller) obligations

The Operator warrants that it has a lawful basis to collect Tenant Personal Data and to provide it to Stowlane for processing, that it has given any required notices to its tenants, and that its instructions comply with applicable law.

4. Confidentiality

Stowlane will keep Tenant Personal Data confidential and ensure that personnel authorized to process it are bound by confidentiality obligations and access it only as needed to provide the Service.

5. Sub-processors

The Operator authorizes Stowlane to engage sub-processors to provide the Service. Each sub-processor is bound by data-protection obligations no less protective than this DPA. The current sub-processors are:

(Plus a reputable cloud hosting/database provider used to run the Service.) Stowlane will give the Operator reasonable notice of any intended addition or replacement of a sub-processor, and the Operator may object on reasonable data-protection grounds.

6. Security measures

Stowlane implements appropriate technical and organizational measures to protect Tenant Personal Data, including:

• encryption in transit (TLS/HTTPS);
• encryption at rest, including application-level field-level encryption of sensitive Tenant Personal Data — tenant names, addresses, phone numbers, email addresses, and gate codes are encrypted at the application layer in the database;
• per-Operator logical isolation of data so one Operator cannot access another's data;
• access controls, least-privilege administrative access, and secure credential handling;
• secure software-development and dependency practices.

7. Personal data breach notification

Stowlane will notify the Operator without undue delay after becoming aware of a personal data breach affecting Tenant Personal Data, and will provide information reasonably available to it to help the Operator meet its own breach-notification obligations. Stowlane will take reasonable steps to mitigate and remediate the breach.

8. Assistance to the Controller

Taking into account the nature of the processing, Stowlane will provide reasonable assistance to the Operator in responding to tenant data-subject requests (access, correction, deletion, portability) and in meeting the Operator's security, breach-notification, and impact-assessment obligations.

9. Return or deletion on termination

On termination or expiry of the subscription, Stowlane will, at the Operator's choice and within a reasonable period, make Tenant Personal Data available for export and then delete or return it, except to the extent Stowlane is required by law to retain a copy. Sub-processors will delete their copies in the ordinary course.

10. Audit and records

Stowlane will make available to the Operator information reasonably necessary to demonstrate compliance with this DPA. Any on-site audit rights are subject to reasonable notice, confidentiality, and frequency limits, and must not compromise the security or data of other Operators.

11. Governing terms

This DPA is governed by the same law and venue as the Terms of Service (Commonwealth of Kentucky; Nelson County, Kentucky, placeholder). In case of conflict between this DPA and the Terms as to the processing of Tenant Personal Data, this DPA controls.