Data Processing Agreement

Last Updated: 10-11-25

This Data Processing Agreement (“Agreement”, “DPA”) forms part of the Terms of Service or other written or electronic agreement (“Principal Agreement”) between:

(1) Controller:
The customer or organization that determines the purposes and means of processing Personal Data (“Customer”, “Controller”, “you”).

(2) Processor:
POSEBEN TECHNOLOGIES LLP, with its registered office at:
1st floor, CC 54, 2593-5, Bose Nagar, Kadavanthra, Kochi, Ernakulam, Kerala, 682020, India (“Processor”, “Gamalogic”,“we”, “us”, or “our”).

Together referred to as the “Parties”.

1. Purpose

This DPA sets out the terms and conditions governing the processing of Personal Data by the Processor on behalf of the Controller, in connection with the provision of email validation, email finder, and related data services (“Services”), as defined in the Principal Agreement.

2. Definitions

  • “Personal Data” means any information relating to an identified or identifiable natural person.
  • “Processing”, “Data Subject”, “Supervisory Authority”, “Controller”, and “Processor” have the meanings given.
  • “Sub processor” means any third party engaged by the Processor to process Personal Data on behalf of the Controller.
  • “Applicable Law” means all data protection laws and regulations applicable to the processing of Personal Data.

3. Roles of the Parties

  • The Controller determines the purpose and means of processing Personal Data.
  • The Processor acts only on the documented instructions of the Controller and will not process Personal Data for any purpose other than to provide the Services.

4. Scope and Nature of Processing

  • Subject Matter: Email validation, email finder, and related services.
  • Nature and Purpose: Processing of email addresses and metadata for validation, verification, and enrichment.
  • Type of Personal Data: Email addresses, IPs, metadata, or related identifiers.
  • Categories of Data Subjects: End users, subscribers, or contacts provided by the Controller.
  • Retention Period: Data is deleted as per customer’s request unless otherwise required by law.

5. Processor Obligations

  • Process only under documented instructions from the Controller.
  • Ensure that all personnel authorized to process Personal Data are bound by confidentiality.
  • Implement appropriate technical and organisational measures to protect data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
  • Assist the controller in fulfilling its obligations regarding data subject requests, breach notifications, and impact assessments.
  • Maintain a record of processing activities and make it available to supervisory authorities upon request.
  • Ensure secure data deletion or return upon termination of services.

6. Controller Obligations

  • It has a lawful basis for the collection and processing of Personal Data.
  • It has provided appropriate privacy notices to data subjects.
  • It will not instruct the Processor to process data in violation of Applicable Laws.
  • It is solely responsible for the accuracy, quality, and legality of Personal Data.

7. Sub Processors

  • The Controller authorizes the Processor to engage Sub processors for providing infrastructure, analytics, and support services.
  • The Processor maintains an up to date list of Sub processors available upon request.
  • The Processor shall enter into written agreements with all Sub processors imposing data protection obligations equivalent to this DPA.

8. Security Measures

  • Network firewalls, DDoS protection, and monitoring systems
  • Regular security audits and penetration testing
  • Incident response procedures and breach notification policies

Details of these measures are described in our Security and Data Protection Policy at www.gamalogic.com/Data-Processing-Agreement/.

9. International Data Transfers

  • The Processor may transfer Personal Data outside the EEA, UK, or Canada where necessary to provide the Services.

10. Data Subject Rights

The Processor shall, to the extent permitted by law, assist the Controller in responding to requests from data subjects exercising their rights under Applicable Laws, including:

  • Right of access, rectification, erasure, restriction, portability, and objection.

All such requests shall be promptly communicated to the Controller.

11. Audit and Compliance

  • The Processor shall make available all information necessary to demonstrate compliance with this DPA.
  • Upon reasonable notice, the Controller may conduct an audit or inspection (or appoint an independent auditor) limited to data protection practices.
  • Both Parties shall cooperate fully in any regulatory investigation or inquiry.

12. Governing Law and Jurisdiction

This DPA shall be governed by the laws of India.

13. Term and Termination

This DPA remains in effect for as long as the Processor processes Personal Data on behalf of the Controller, or until the Principal Agreement is terminated.

14. Miscellaneous

  • If any provision of this DPA is invalid or unenforceable, the remaining provisions shall remain in full force and effect.
  • In case of conflict between this DPA and the Principal Agreement, the terms of this DPA shall prevail to the extent of the conflict regarding data protection matters.

15. Contact Information

POSEBEN TECHNOLOGIES LLP
Attn: Data Protection Officer
Email: info@gamalogic.com
Website: www.gamalogic.com
Address: 1st floor, CC 54, 2593-5,
Bose Nagar, Kadavanthra, Kochi,
Ernakulam, Kerala, 682020

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