Data Processing Addendum
This draft describes proposed terms for a trader using Pitchtivo to process personal data about that trader’s customers. It is not yet an executed agreement and should be checked against the final service, provider contracts and legal advice before relying on it.
1. Parties and scope
The trader is the controller for personal data the trader places in the Pitchtivo service about customers, staff or other individuals. Tony Silburn-Guy trading as Pitchtivo is the processor for that data only to provide, support, secure and maintain the service on the trader’s documented instructions. Pitchtivo remains a separate controller for trader account administration, its own security, support and service operations.
2. Processing description
Subject matter and duration: providing the Pitchtivo service during the trader’s account term and any limited period required to return or delete data.
Nature and purposes: hosting, storing, displaying, organising, backing up, exporting and deleting workspace records; supporting orders, food-safety records, menus, staff and business operations; maintaining security and troubleshooting.
Data subjects: the trader’s customers and prospective customers, the trader’s workers, suppliers and other people whose details the trader enters.
Data types: names, contact details, order/menu selections, collection times and messages; staff names/roles/shift records; supplier and business contact details; photos and documents the trader uploads; and other information the trader chooses to enter. The service is not designed for special-category or criminal-offence data. The trader must not submit such data unless the parties first agree suitable safeguards and a lawful basis.
3. Trader instructions and responsibilities
The trader instructs Pitchtivo to process data only as needed to provide the enabled service features and as further documented by the trader’s configuration, support requests and this addendum. The trader is responsible for lawful basis, transparency to individuals, data minimisation, accuracy, access permissions, retention decisions, and responding to rights requests unless the law requires Pitchtivo to assist.
4. Pitchtivo commitments
Pitchtivo will: (a) process covered personal data only on documented instructions, unless law requires otherwise; (b) ensure authorised people are bound by confidentiality; (c) maintain appropriate technical and organisational safeguards; (d) provide reasonable assistance with data-subject requests, security, breach notification, impact assessments and regulator consultation, taking account of the processing and information available; (e) notify the trader without undue delay after becoming aware of a personal-data breach affecting the trader’s data; and (f) make available information reasonably necessary to demonstrate compliance and support reasonable audits, subject to confidentiality, security and proportionate notice.
5. Sub-processors and transfers
The trader gives no blanket approval by viewing this draft. Before this addendum is activated, Pitchtivo must publish and maintain a current sub-processor list identifying the provider, service, data involved, processing location and transfer mechanism where relevant; contractually flow down equivalent data-protection duties; and provide notice of proposed changes with a reasonable opportunity to object. Current providers and transfer safeguards have not yet been fully contract-verified. No international transfer mechanism is promised by this draft.
6. Return and deletion
At account end, the trader may request export of available data. Pitchtivo will delete or return covered data on the trader’s documented choice, unless applicable law requires retention. Backup copies may remain inaccessible in routine backups until the verified backup cycle expires, and remain protected during that period. The current service does not yet provide complete self-service deletion; the parties must agree and operationalise a request process before this addendum is relied on.
7. Security schedule
Safeguards currently identified in the reviewed application include TLS redirection and security headers, secure HTTP-only SameSite session cookies, password hashing, CSRF protections, multi-factor authentication support, organisation-scoped records, role checks, rate limiting, private safety-document storage, and exclusion of API data from the service-worker cache. These measures may change. Hosting, backup, monitoring, access, key-management, incident and recovery controls must also be verified with the hosting provider and through operational evidence. This schedule is not a guarantee against incidents.
8. Priority and contact
This draft does not override mandatory law. The parties should complete and sign a final version that identifies the trader, service term, current sub-processors, transfer arrangements, security details, retention/deletion process and notice channels. Contact [email protected].