Data Processing Agreement

1. Definitions

“Personal Data” means any information relating to an identified or identifiable natural person. “Processing” means any operation performed on Personal Data, including collection, storage, use, and disclosure.

2. Roles and Responsibilities

Startswith Agency acts as a Data Processor. Our clients act as Data Controllers for the prospect data they provide. We process Personal Data only on documented instructions from the Controller.

3. Processing Activities

We process Personal Data for the following purposes:

• • Prospect research and verification
• • Outreach campaign execution
• • Performance tracking and reporting
• • Communication scheduling and coordination

4. Security Measures

We implement appropriate technical and organizational measures to protect Personal Data, including encryption, access controls, and regular security audits.

5. Data Subject Rights

We assist our clients in fulfilling Data Subject requests including access, rectification, erasure, and portability rights as required by applicable law.

6. Data Retention and Deletion

We retain Personal Data only for the duration of our engagement and delete all data within 30 days of contract termination, unless legally required otherwise.