Data Processing Addendum (DPA)

Effective Date: February 21, 2025

Parties:

• HousingComply LLC ("Processor" or "HousingComply")
• The customer or entity agreeing to the Terms & Conditions ("Controller" or "Customer")

This Data Processing Addendum ("Addendum") supplements the Terms & Conditions (the "Agreement") entered into between the Parties. It governs HousingComply's processing of Personal Data on behalf of the Customer.

1. Definitions

For purposes of this Addendum:

• "Personal Data" means any information relating to an identified or identifiable natural person that is processed under the Agreement.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.
• "Controller" means the entity that determines the purposes and means of Processing Personal Data (Customer).
• "Processor" means the entity that processes Personal Data on behalf of the Controller (HousingComply).
• "Sub-processor" means any third party engaged by HousingComply to assist in Processing Personal Data.
• "Applicable Data Protection Laws" includes the EU General Data Protection Regulation (GDPR), UK GDPR, and the California Consumer Privacy Act (CCPA/CPRA), to the extent applicable.

2. Roles of the Parties

• Customer acts as Controller of Personal Data.
• HousingComply acts as Processor, processing Personal Data solely for the purposes of providing the Services under the Agreement.
• Both Parties agree to comply with Applicable Data Protection Laws.

3. Nature & Purpose of Processing

• Subject matter: AI-driven compliance and document analysis services.
• Duration: For the term of the Agreement, unless otherwise required by law.
• Nature of processing: Storage, analysis, transmission, and reporting of Customer Data.
• Purpose: To provide and improve HousingComply's Services in accordance with the Agreement.
• Categories of data subjects: Customer's employees, clients, contractors, or other individuals whose data is contained in submitted documents.
• Types of data: Names, contact details, identification information, compliance-related data, and other document contents as provided by Customer.

4. HousingComply's Obligations (Processor)

HousingComply shall:

1. Process Personal Data only in accordance with Customer's documented instructions.
2. Implement appropriate technical and organizational security measures to protect Personal Data.
3. Ensure personnel authorized to process Personal Data are subject to confidentiality obligations.
4. Not sell, rent, or disclose Personal Data except as permitted under the Agreement or required by law.
5. Notify Customer without undue delay in the event of a confirmed Personal Data breach.
6. Assist Customer with responding to data subject requests (access, deletion, correction, portability).
7. Maintain records of processing activities as required by law.

5. Customer's Obligations (Controller)

The Customer shall:

1. Ensure that its instructions to HousingComply comply with Applicable Data Protection Laws.
2. Provide all necessary notices and obtain all required consents from data subjects.
3. Be solely responsible for the accuracy, quality, and legality of Personal Data submitted.

6. Sub-Processors

• Customer authorizes HousingComply to engage sub-processors for hosting, storage, analytics, and operational support.
• HousingComply will maintain a list of sub-processors and notify Customer of material changes.
• HousingComply will ensure sub-processors are bound by written agreements providing at least the same level of protection.

7. International Transfers

• Personal Data may be transferred to and processed in the United States and other jurisdictions.
• Where required, HousingComply will implement safeguards (e.g., Standard Contractual Clauses, adequacy decisions) to ensure lawful transfers.

8. Data Subject Rights

HousingComply will:

• Promptly forward any request received from a data subject to the Customer.
• Provide reasonable assistance for Customer to respond to such requests.

9. Data Security & Breach Notification

• HousingComply will implement and maintain security measures appropriate to the risks of processing.
• In case of a Personal Data breach, HousingComply will notify Customer without undue delay, providing details of the breach, likely consequences, and remediation steps.

10. Return or Deletion of Data

Upon termination of Services, HousingComply will:

• Delete or return all Personal Data to Customer upon request, unless retention is required by law.
• Securely delete any remaining copies after the retention period.

11. Audits

• HousingComply will provide reasonable evidence of compliance (e.g., security certifications, summaries of audits).
• Customer may request, at its own expense, additional audits or inspections, subject to confidentiality and operational constraints.

12. Liability

The Parties' liability under this Addendum shall be subject to the limitations of liability set forth in the Agreement.

13. Miscellaneous

• This Addendum prevails over conflicting provisions of the Agreement with respect to data protection.
• If any provision is invalid, the remaining provisions remain in effect.
• This Addendum is governed by the laws of South Dakota, United States, unless otherwise required by Applicable Data Protection Laws.

14. Contact Information

Questions regarding this DPA may be directed to: