Data Processing Addendum
This Data Processing Addendum ("DPA") forms part of the agreement between the customer ("Controller") and KwikCall AI LLC ("NumberFlare", "Processor") for the processing of personal data in connection with the Service. It reflects generally accepted data-processing principles; a signed copy is available on request at [email protected].
1. Roles
With respect to the personal data of the individuals the customer contacts through the Service ("Customer Personal Data"), the customer is the Controller and determines the purposes and means of processing. NumberFlare acts as the Processor and processes Customer Personal Data solely on the customer's documented instructions.
2. Scope & purpose of processing
- Subject matter: provision of the NumberFlare cloud communications platform (phone numbers, calls, SMS and WhatsApp messaging).
- Categories of data subjects: the customer's contacts and call recipients.
- Categories of data: phone numbers, names and custom fields uploaded by the customer; call recordings.
- Duration: the term of the agreement, plus the retention period configured by the customer.
3. Processor obligations
- Process Customer Personal Data only on the customer's instructions and for the purpose of providing the Service.
- Ensure persons authorised to process the data are bound by confidentiality.
- Implement appropriate technical and organisational security measures (Section 5).
- Assist the customer, taking into account the nature of processing, in responding to data-subject rights requests and in meeting breach-notification and security obligations.
- Delete or return Customer Personal Data at the end of the agreement, subject to legal retention requirements.
4. Sub-processors
The customer authorises NumberFlare to engage the sub-processors listed in our Privacy Policy (Telnyx, Meta/WhatsApp, Hetzner, Stripe). NumberFlare imposes data-protection obligations on each sub-processor and remains responsible for their performance. We will give at least 30 days' notice before adding a materially new sub-processor.
5. Security measures
- Encryption of data in transit (TLS) and at rest.
- Role-based access controls and least-privilege access.
- Logging, monitoring and periodic backups.
- Secret management and network isolation for production systems.
6. Breach notification
NumberFlare will notify the customer without undue delay after becoming aware of a personal-data breach affecting Customer Personal Data, and will provide information reasonably needed for the customer to meet its own notification obligations to affected individuals and any applicable regulators.
7. International processing
Processing and storage may occur in the United States and other jurisdictions where NumberFlare or its sub-processors operate (e.g. Hetzner in Germany). Where personal data is transferred across borders, NumberFlare applies appropriate safeguards consistent with applicable data-protection law.
8. Contact
Requests relating to this DPA: [email protected] · KwikCall AI LLC, 1209 Mountain Road Pl NE, #4948, Albuquerque, NM 87110, USA.