These Data Processing Terms form part of the CozyHalls Terms of Service between the hall ("the controller") and CozyHalls ("the processor", "we"). They set out the terms required by Article 28 of the UK GDPR and the Data Protection Act 2018.
1. Roles
The hall decides why and how its customers' personal data is collected through its booking site, so the hall is the controller. CozyHalls hosts the site and processes that data only on the hall's behalf, so CozyHalls is the processor.
CozyHalls is a separate controller for the details of the hall's own contacts and administrators that we use to run our relationship with the hall (for example, the signup details and account emails).
2. What we process
- Subject matter and purpose: hosting the hall's booking website and providing booking, enquiry, invoicing and email features.
- Duration: for as long as the hall uses the service, and afterwards only as set out in section 9.
- Data subjects: people who make bookings or enquiries with the hall, and the hall's administrators.
- Categories of data: names, contact details (email, phone, postal address), organisation names, booking details (dates, times, spaces, number of attendees, notes), enquiry messages, invoice details, and technical data such as hashed IP addresses used for spam prevention and visitor statistics.
- Special category data: the service is not designed for it. Halls should not ask customers for health or other special category data through the booking forms.
3. Our obligations
We will:
- process the personal data only on the hall's documented instructions, which are these terms and the hall's use of the service's settings, unless the law requires otherwise (in which case we will tell the hall unless the law forbids it);
- ensure that everyone authorised to process the data is bound by confidentiality;
- take appropriate technical and organisational security measures, including encryption in transit, access controls and regular backups;
- only use sub-processors as described in section 4;
- help the hall, taking into account the nature of the processing, to respond to requests from people exercising their data protection rights, and to meet its obligations on security, breach notification and data protection impact assessments;
- make available the information reasonably needed to demonstrate compliance with these terms, and allow for reasonable audits on reasonable notice;
- tell the hall if we think an instruction infringes data protection law.
4. Sub-processors
The hall gives general authorisation for us to use sub-processors. Our current sub-processors are:
- DigitalOcean — server and database hosting;
- Postmark (ActiveCampaign) — sending emails from the booking site;
- Rollbar — error monitoring (may receive limited technical data when an error occurs).
[Hosting regions and transfer safeguards to be confirmed.] We will give at least 30 days' notice of any new sub-processor, during which the hall may object. We impose data protection obligations on each sub-processor equivalent to these terms and remain responsible for their performance.
5. International transfers
We will not transfer the personal data outside the UK unless the transfer is covered by UK adequacy regulations or appropriate safeguards (such as the UK International Data Transfer Agreement or Addendum).
6. Personal data breaches
We will notify the hall without undue delay after becoming aware of a personal data breach affecting its data, with the information the hall reasonably needs to meet its own obligations, including any report to the Information Commissioner's Office.
7. The hall's responsibilities
The hall is responsible for having a lawful basis for the data it collects, for publishing an accurate privacy notice on its site, for the instructions it gives through the service's settings, and for keeping its administrator accounts secure.
8. Retention
The service lets the hall configure how long data is kept. Unless the hall changes them, the defaults are: booking and enquiry details are anonymised two years after the booking date, and invoices are kept for six years. The hall can also erase an individual's data on request.
9. End of the service
When a site is closed, we will give the hall a reasonable opportunity to export its data, then delete the personal data from the live service within 30 days and from backups within a further 90 days, unless the law requires us to keep it.
10. Contact
Data protection questions: [data protection contact email — to be confirmed], or use our contact page.