Data Processing Addendum (summary)

Last updated October 17, 2026.

This DPA forms part of the Terms when ClientUnlocked processes personal data on a customer's behalf (GDPR Art. 28, UK GDPR, CCPA service-provider terms).

• Roles: Customer is controller; ClientUnlocked is processor.
• Instructions: we process prospect data only to provide the Service as configured by the customer.
• Confidentiality: staff with access are bound by confidentiality.
• Security: measures listed in our Privacy Policy, reviewed at least annually.
• Sub-processors: listed in the Privacy Policy; 30 days' notice of changes with a right to object.
• Assistance: we help with data-subject requests (built-in export and erasure) and DPIAs.
• Breach notice: without undue delay and within 48 hours of becoming aware.
• Deletion: on termination, data is deleted within 30 days unless law requires retention.
• Transfers: EU SCCs (Module 2/3) and UK Addendum incorporated by reference.
• Audits: on reasonable notice, once per year, or via third-party reports.

Processor: Ase Studios, LLC, 18 India Street Brooklyn NY 11222. To request a countersigned copy: legal@clientunlocked.com