data processing addendum

Use: any fleets customer subject to GDPR / UK GDPR / EU-equivalent rules who installs the fleets pixel on their site, where fleets becomes a Data Processor acting on the customer's instructions. This document is a template. To execute, both parties countersign with their legal names and the effective date.

1. Definitions

2. Subject matter

fleets processes pixel telemetry on behalf of the Controller for the sole purpose of producing aggregated traffic + bot-rate analytics.

3. Categories of data subjects

Visitors to the Controller's website.

4. Categories of personal data

No special-category data (GDPR Art. 9) is processed.

5. Duration of processing

Raw events are retained for 90 days, aggregates for 18 months, unless the Controller terminates the agreement, in which case raw events are deleted within 30 days and aggregates within 90 days.

6. Processor obligations

7. Sub-Processors

| processor | role | location | |---|---|---| | Cloudflare | edge ingest, TLS, fingerprint | global | | Google Cloud (us-central1) | storage, processing | USA |

The Controller may object to new Sub-Processors with 30 days written notice; absent objection, consent is deemed granted.

8. International transfers

EU-origin data may be transferred to the USA under the EU-U.S. Data Privacy Framework (Google Cloud, Cloudflare both certified). If the framework is invalidated, fleets and Controller will execute the EU Standard Contractual Clauses without delay.

9. Audit

Controller may request an audit no more than once per twelve months, with 30 days written notice. fleets will provide an industry-recognized attestation (e.g. SOC 2 Type II) in lieu of an on-site audit when available.

10. Liability

Each party's aggregate liability under this DPA is capped at fees paid by the Controller in the twelve months preceding the incident.

11. Governing law

Same as the main service agreement between the parties.

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Controller: _____________________________ date: ________________

Processor (fleets.run): __________________ date: ________________