Data Processing Addendum

This DPA supplements the Terms between the customer as controller/business and Luo Liqiang as processor/service provider for Customer Data.

Instructions and purpose

We process account, customer, transaction, document and workflow data only to provide, secure and support LedgerChase, comply with documented customer instructions and law, and do not sell or use Customer Data for targeted advertising.

Confidentiality and security

Authorized personnel are bound by confidentiality and least privilege. We maintain proportionate technical and organizational measures, incident response, access controls, encryption, malware defenses, logging, backups and recovery procedures.

Subprocessors and transfers

Customer authorizes the listed subprocessors. We impose data-protection obligations appropriate to their role and remain responsible for our processor duties. Material changes will be notified where configured, with a reasonable opportunity to object on substantiated data-protection grounds. Locations and providers appear in the Subprocessors List.

Assistance

Taking account of processing and information available, we assist with data-subject requests, security incidents, impact assessments and regulator consultations. Customer remains responsible for lawful instructions, notices, legal basis and its own systems.

Deletion, audit and conflict

At termination, we return or delete Customer Data subject to documented retention and legal obligations. We provide relevant documentation and reasonable audit cooperation, with safeguards for other customers and security. Privacy-law mandatory terms prevail over conflicting commercial terms.

Details

Duration: account/service term plus retention period. Subjects: customer personnel, clients, vendors and persons in uploaded records. Categories: identifiers, contacts, financial/workflow information, documents, audit/security metadata; potentially sensitive financial data. Contact: [email protected].