1. Parties and priority
This DPA supplements the Terms between the customer (Controller/Business) and Accordelle’s legal operator (Processor/Service Provider). If it conflicts with the Terms on processing customer personal data, this DPA controls.
2. Processing details
Subject matter: providing Accordelle. Duration: the agreement plus deletion/return period. Nature and purpose: hosting, organizing, extracting, comparing, securing, supporting, and transmitting HOA request information under customer instructions. Data subjects may include homeowners, residents, applicants, board/committee members, managers, contractors, and customer personnel. Data types are described in the Privacy Policy and may include identifiers, property/project details, communications, files, account records, and audit events.
3. Instructions and restrictions
Accordelle will process customer personal data only on documented customer instructions, including the Terms and configured use, unless law requires otherwise. Accordelle will not sell or share the data for cross-context behavioral advertising, retain/use/disclose it outside the business purpose, or combine it with unrelated personal data except as legally permitted.
4. Confidentiality and security
Personnel authorized to process customer data will be bound by confidentiality. Accordelle maintains measures appropriate to risk, including access control, authentication, tenant separation, encryption in transit, protected storage, logging, backup and recovery procedures, and incident response.
5. Subprocessors
Customer authorizes Accordelle to use service providers needed for hosting, storage, authentication, payments, communications, support, and document analysis, subject to appropriate contractual protections. Current categories include OpenAI Sites and Cloudflare infrastructure, Google Gemini for enabled AI analysis, and Stripe for billing. Accordelle remains responsible for its subprocessor obligations to the extent required by law.
6. Individual requests
Taking into account the nature of processing, Accordelle will reasonably assist customers with verified requests to access, correct, delete, restrict, or obtain personal data. Accordelle will not independently respond on customer-controlled data except as instructed or legally required.
7. Security incidents
Accordelle will notify the customer without undue delay after confirming a personal-data breach affecting customer data and provide available information reasonably needed for the customer’s legal obligations. Notification is not an admission of fault.
8. Assessments and audits
Accordelle will provide information reasonably necessary to demonstrate compliance and support legally required impact assessments. Audits must protect other customers, security, and confidential information and should first use current independent reports or questionnaires when available.
9. Return and deletion
At termination or written instruction, Accordelle will delete or return customer data unless continued retention is required by law, needed to resolve a dispute, or reasonably necessary for security and fraud prevention. Backup copies remain protected and are removed through ordinary backup rotation.
10. Transfers and governing law
The parties will implement legally required transfer safeguards when applicable. This DPA is governed by Arizona law unless applicable privacy law requires otherwise. Additional security, subprocessor, or international-transfer terms may be documented in writing for an enterprise agreement.