Effective Date: This Agreement is effective as of the date Customer accepts these terms or begins using Happierleads services.

This Data Processing Agreement ("DPA") forms part of the Terms of Service between Happierleads Ltd ("Happierleads", "we", "us") and the entity agreeing to these terms ("Customer", "you") and governs the processing of personal data in connection with our services.

"Controller" means the entity that determines the purposes and means of processing Personal Data. For Customer Data, Customer is the Controller. For Enrichment Data, Happierleads is the Controller or has obtained such data from third-party controllers.

"Processor" means the entity that processes Personal Data on behalf of a Controller.

"Customer Data" means Personal Data that Customer uploads, provides, or makes available to Happierleads through the Services, including website visitor IP addresses and behavioral data collected via the tracking pixel.

"Enrichment Data" means Personal Data that Happierleads provides to Customer, including company information, contact details, and person-level identification data sourced from Happierleads' databases and third-party partners.

"Personal Data", "Processing", "Data Subject", "Personal Data Breach", and "Supervisory Authority" have the meanings given in the GDPR (EU Regulation 2016/679).

2.1 Customer Data (Happierleads as Processor)

With respect to Customer Data, Customer is the Controller and Happierleads acts as a Processor. Happierleads will process Customer Data only in accordance with Customer's documented instructions and this DPA.

2.2 Enrichment Data (Happierleads as Controller/Data Provider)

With respect to Enrichment Data, Happierleads acts as an independent Controller or as a provider of data obtained from third-party sources. This data is licensed to Customer under the Terms of Service. Customer becomes a Controller of such data upon receipt and is solely responsible for its lawful use.

IMPORTANT: Our identification capabilities differ by region:

Customer represents, warrants, and undertakes that:

When processing Customer Data as a Processor, Happierleads shall:

Customer provides general authorization for Happierleads to engage sub-processors. Happierleads maintains a list of current sub-processors, which is available upon request. Happierleads will notify Customer of any intended changes to sub-processors, and Customer may object within 14 days on reasonable grounds. Sub-processors are bound by data protection obligations equivalent to those in this DPA.

Where Customer Data is transferred outside the EEA/UK to countries not deemed adequate by the European Commission, Happierleads ensures appropriate safeguards are in place, including:

Happierleads implements and maintains appropriate technical and organizational measures to protect Personal Data, including:

Happierleads will assist Customer in fulfilling Data Subject rights requests (access, rectification, erasure, restriction, portability, objection) to the extent the request relates to Customer Data. Customer is responsible for responding to such requests. Happierleads will notify Customer promptly if it receives a request directly from a Data Subject, unless prohibited by law.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

Customer agrees to indemnify, defend, and hold harmless Happierleads, its officers, directors, employees, and agents from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising from or related to:

Upon reasonable request (no more than once per year) and with at least 30 days' written notice, Customer may request that Happierleads provide documentation demonstrating compliance with this DPA. Happierleads may satisfy audit requests by providing copies of certifications, audit reports, or other documentation. On-site audits require mutual agreement and Customer shall bear all costs associated with such audits.

This DPA shall remain in effect for the duration of Customer's use of the Services. Upon termination, Happierleads will delete Customer Data within 30 days unless retention is required by law. Customer's obligations regarding the use of Enrichment Data survive termination.

This DPA shall be governed by the laws of England and Wales. Any disputes arising under this DPA shall be subject to the exclusive jurisdiction of the courts of England and Wales.

A. Subject Matter and Purpose of Processing

Website visitor identification, company enrichment, lead generation, and analytics services.

Website visitors, business professionals, and corporate employees whose information is publicly available or obtained through consented channels.

For the term of Customer's subscription plus 30 days, unless Customer requests earlier deletion.

By using Happierleads services, Customer acknowledges and agrees to this DPA. This DPA is designed to be signed electronically through acceptance of our Terms of Service. For enterprise customers requiring a separately executed DPA, please contact legal@happierleads.com.

PERSONAL DATA PROCESSING AGREEMENT Introduction This Personal Data Processing agreement (” Agreement ”) shall be applied to all products and services...

DPA (Data Processing Agreement)

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