Data Processing Addendum

PLCloaker (the “Service”) is operated by [Company legal name], [Registered address] (“we”, “us”). Contact: info@adclickpath.com.

This addendum is part of the Terms of Service and applies when we process personal data on behalf of a customer (the “Controller”) as a processor.

1. Scope

• Subject matter: hosting and delivering the Controller’s pages, filtering and routing clicks, and storing leads.
• Data subjects: visitors of the Controller’s pages and people who submit forms on them.
• Data: tracking parameters, IP-derived country and city, referrer, user agent, visit counters and submitted form fields such as an email address.
• Duration: for as long as the Controller uses the Service.

2. Instructions

We process the data only on the Controller’s documented instructions, which are given through the settings of the Service and these terms, unless the law requires otherwise.

3. Controller obligations

The Controller is responsible for the lawful basis, the notices and any consent required for the data collected on its pages, and for answering data subject requests.

4. Confidentiality and security

People who access the data for us are bound by confidentiality. We apply appropriate technical and organizational measures, including separation of data per organization, access control, encrypted transport and hashed credentials.

5. Sub-processors

The Controller authorizes Cloudflare, Inc. (hosting, storage, databases, email delivery) and the AI model providers reached through Cloudflare AI Gateway (page generation). We will announce new sub-processors on this page before they start; the Controller may object on reasonable grounds.

6. International transfers

Where data leaves the country of origin, we rely on standard contractual clauses or an equivalent safeguard where the law requires one.

7. Assistance

We help the Controller answer data subject requests and meet its security, breach notification and impact assessment duties, taking the nature of the processing into account. The Service lets the Controller filter, export and purge leads directly.

8. Personal data breaches

We will notify the Controller without undue delay after becoming aware of a breach affecting its data, with the information we have.

9. Deletion

When the Controller deletes data or its organization, we delete the data from the live systems. Backups expire on their own schedule.

10. Audits

On request we provide the information needed to show compliance with this addendum, and allow an audit once a year with reasonable notice, at the Controller’s cost and without access to other customers’ data.

11. Contact

For a signed copy or questions: info@adclickpath.com.