Data Processing Agreement

This Data Processing Agreement ("Agreement") sets out the terms under which Recur Ltd, also known as “Recur”, processes personal data on behalf of clients who engage with its services ("Controller").

By using Recur’s services, the Controller accepts and agrees to be bound by the terms of this Agreement.

1. Purpose and Scope

1.1 Recur shall process personal data solely for the purpose of sending review requests to customers on behalf of the Controller.

1.2 The Controller confirms that all personal data shared with Recur has been obtained lawfully and that customers have agreed to receive communications for the legitimate purpose of feedback and review requests.

2. Data Processed

2.1 Categories of personal data processed may include:

• Name

• Email address

• Phone number

2.2 No special category (sensitive) data is processed under this Agreement.

3. Obligations of the Parties

3.1 Controller Responsibilities:

• Ensure all shared data has been lawfully obtained.

• Confirm customer consent to receive review and feedback communications.

• Handle any data subject rights requests regarding the data provided.

3.2 Processor (Recur) Responsibilities:

• Process data only for the specified purposes in this Agreement.

• Implement appropriate security measures to protect data.

• Delete or return personal data upon termination unless retention is legally required.

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4. Security & Data Breaches

4.1 Recur shall take reasonable steps to protect personal data from unauthorised access, loss, or misuse.

4.2 In the event of a data breach, Recur will notify the Controller without undue delay.

5. Data Retention & Deletion

5.1 Upon termination of services, Recur shall securely delete all personal data unless retention is required by applicable law.

6. Use of Sub-Processors

6.1 Recur may use sub-processors to deliver its services, provided such sub-processors are bound by the same data protection obligations.

6.2 Recur remains responsible for the actions of its sub-processors.

7. General Terms

7.1 This Agreement remains in effect for the duration of the Controller’s engagement with Recur.

7.2 Either party may terminate this Agreement with 14 days' written notice.

7.3 This Agreement is governed by the laws of England and Wales.

Effective Date: This Agreement is effective from the date the Controller first uses Recur’s services.