Last updated Aug 2026
Data Processing Addendum
Terms for any personal data we process on your behalf — kept minimal by design, because the product holds none.
Trial template — placeholder legal copy. Replace with counsel-reviewed text before launch.
01Purpose
This Data Processing Addendum supplements the Terms where FirstSeen processes any personal data on your behalf. In practice this is limited to customer account and integration data, since the product data contains no personal data.
02Roles
For product data, FirstSeen is an independent controller of public-source records. For customer account data, FirstSeen is a processor acting on your instructions.
03Scope of processing
Categories are limited to business account details and integration metadata (e.g. webhook destinations). No special-category data, no consumer PII.
04Sub-processors
A current list of sub-processors (hosting, payments, transactional email) is maintained and available on request; we give notice of material changes.
05Security
We apply appropriate technical and organisational measures: encryption in transit, least-privilege access, and secrets resolved at runtime rather than stored on disk.
06International transfers
Where data leaves the EEA it is covered by Standard Contractual Clauses or an adequacy decision.
07Sub-processing & audit
You may request reasonable information to demonstrate compliance. Sub-processors are bound by equivalent obligations.
08Return & deletion
On termination we return or delete customer personal data after the statutory minimum retention.