PerkSpringLegalDPA

Data Processing Agreement

Based on Common Paper DPA v1.1 (CC BY 4.0)

Cover Page

ProviderPerkSpring, Inc.
ServicesPrivacy-preserving member verification platform
Data ProcessingSHA-256 hashed email addresses (pseudonymized personal data)
Processing PurposeMember verification between membership organizations and retailers
Data SubjectsMembers of partner membership organizations
Applicable LawUK GDPR / EU GDPR / CCPA as applicable
Sub-Processors/legal/sub-processors
Erasure SLA30 days from request (Article 17)
Breach Notification72 hours from discovery (Article 33)
Data RetentionHashed data retained until erasure requested or partnership terminated
Special Category DataMembership of certain organizations (e.g. trade unions, military and first-responder groups) may constitute Article 9 special-category data. Verification results disclose the organization name.
AI Agent AccessThird-party AI shopping agents may query verification only for retailers that have explicitly authorized them. Authorization is retailer-granted, revocable at any time, and recorded in the audit log.
Technical MeasuresPer-org salted SHA-256 hashing, TLS in transit, encrypted at rest, role-based access control, per-agent and per-subject rate limiting

Standard Terms Incorporation

This DPA incorporates Common Paper's Standard DPA Terms v1.1, including post-Schrems II Standard Contractual Clauses (EU Implementing Decision 2021/914), UK GDPR Addendum, and CCPA service provider language.

Full Standard Terms: commonpaper.com/standards/data-processing-agreement

Contact

For DPA execution, contact [email protected]