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
Technical MeasuresPer-org salted SHA-256 hashing, TLS in transit, encrypted at rest (Neon), role-based access control

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 legal@perkspring.com