Legal

Data Processing Agreement

How ResellerHQ processes the personal data resellers put into it, as their processor, and the protections it commits to.

This Data Processing Agreement ("DPA") is made up of this Cover Page and the Common Paper Data Processing Agreement Standard Terms, Version 1.1 ("Standard Terms"), published at commonpaper.com/standards/data-processing-agreement/1.1, which are incorporated by reference. If this Cover Page and the Standard Terms conflict, this Cover Page wins. Words with capitals that are not defined here have the meanings given in the Standard Terms.

How this DPA is accepted

This DPA forms part of the ResellerHQ Terms of Service. A reseller accepts it when it accepts the Terms of Service (by creating an account or using the service). A reseller that wants a countersigned copy can ask privacy@resellerhq.com.

Parties

Provider (processor)Customer (controller)
NameEnrich Labs LLC FZ, trading as ResellerHQThe reseller that holds the ResellerHQ account
Address6th Floor, Meydan Grandstand, Meydan Hotel, Meydan, Dubai, United Arab EmiratesThe billing address in the reseller's account
Contact for this DPAprivacy@resellerhq.comThe account owner's email address
Security contactsecurity@resellerhq.comThe account owner's email address

Key terms

TermWhat we agree
AgreementThe ResellerHQ Terms of Service at resellerhq.com/terms
Applicable Data Protection LawsIncludes the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), the GDPR, the UK GDPR and US state privacy laws such as the CCPA, wherever they apply to the Customer Personal Data
Approved SubprocessorsThe subprocessors in the categories listed in Annex III. Their names are in a confidential schedule, which the Provider gives the Customer on request; the Customer keeps it confidential
New SubprocessorsAt least 30 days' notice, by email to the account owner and by updating resellerhq.com/legal/subprocessors, before a new subprocessor receives Customer Personal Data. The Customer may object in writing within that period on reasonable data protection grounds
Security PolicyAnnex II
Breach notificationWithout undue delay, and no later than 48 hours after the Provider becomes aware of a Personal Data Breach affecting Customer Personal Data
Service Provider Relationship (CCPA)The Provider is a service provider. It does not sell or share Customer Personal Data, and does not use it for any purpose other than providing the services
Restricted TransfersThe EU Standard Contractual Clauses, Module 2 (controller to processor) and Module 3 (processor to processor), and the UK Addendum, apply as set out in the Standard Terms
Governing Member State (EU SCCs only)Ireland
Governing law and courtsThe laws of the United Arab Emirates as applied in the Emirate of Dubai, and the courts of Dubai, as in the Agreement. The EU SCCs are governed as they themselves require
AuditsOnce a year, on 30 days' written notice, answered first with written responses and Annex II. On-site audits only where the law requires one or after a Personal Data Breach, at the Customer's cost and under confidentiality
Return and deletionThe Customer can export its data from the dashboard and API at any time. The Provider deletes Customer Personal Data within 30 days of the Customer's written request or of the Customer deleting it in the dashboard, except where the law requires it to be kept. Copies in encrypted backups expire within 400 days and are never restored for any other purpose

Annex I: description of the processing

A. Parties

  • Data exporter (controller): the Customer, which resells domains, phone numbers and Google mailboxes to its own customers.
  • Data importer (processor): the Provider, which runs the ResellerHQ platform described in the Agreement.

B. Description of the processing

ItemDescription
Categories of data subjectsThe Customer's own customers and their staff; people named as domain contacts; users of the mailboxes the Customer orders; people who send SMS to, or call, numbers the Customer rents
Categories of personal dataNames; email addresses; postal addresses; phone numbers; organisation names; tax IDs; domain registrant, admin, tech and billing contacts; mailbox names, email addresses and sign-in details (password, app password, two-step verification secret); SMS sender numbers and message text, and call transcripts; order and invoice details
Sensitive dataNone intended. The Customer must not send special-category data through ResellerHQ. The Provider does not inspect SMS or mailbox content, so the Customer is responsible for what its end users send
FrequencyContinuous, for as long as the Agreement lasts
Nature of the processingStoring, organising and transmitting the data to the providers needed to fulfil an order (domain registrars and registries, the phone number provider, Google), and showing it to the Customer through the dashboard, the API and the assistants the Customer connects
PurposeProviding the ResellerHQ services the Customer orders under the Agreement
Duration and retentionFor the term of the Agreement, until the Customer asks for deletion, then as in "Return and deletion" above
Transfers to subprocessorsOnly the data each subprocessor needs for its function, as described in Annex III

C. Competent supervisory authority

For transfers under the EU SCCs, the supervisory authority of Ireland, unless the SCCs require another. For transfers under the UK Addendum, the UK Information Commissioner's Office.

Annex II: technical and organisational measures

The Provider maintains the measures below, and will not reduce their overall level during the term. A fuller description is available on request from security@resellerhq.com.

AreaMeasures
EncryptionHTTPS (TLS) on every public endpoint. Mailbox sign-in details and other secrets encrypted at rest with a key kept outside the database. Backups encrypted before they leave the database servers
CredentialsPasswords stored only as one-way hashes and checked against known breached passwords. API keys and tokens shown once and stored only as hashes
Access controlEvery record belongs to one reseller account and every request is checked against it. Staff use a separate sign-in with mandatory two-step verification. Database servers reachable only with SSH keys, through a hardened entry server; server access limited to a few named people
NetworkDatabase servers communicate over a private encrypted network, behind firewalls that deny all traffic by default
AvailabilityA three-node database cluster. Nightly full backups, each checked by a test restore, kept off-site with a second provider (daily copies 35 days, monthly copies 400 days)
Monitoring and loggingUptime checks and alerts. Request logs and traces kept 15 days, and never containing request or response content from the API or assistant tools. An activity trail of every change in each account
PatchingAutomatic security updates on database and infrastructure servers
PeopleStaff and contractors are bound by confidentiality. Access is removed when someone leaves
IncidentsA written breach procedure: contain, assess, notify affected Customers within 48 hours, notify authorities where required, and review
SubprocessorsEach is checked before use (data protection agreement, transfer mechanism, security) and bound by data protection terms no less protective than this DPA

Annex III: subprocessors

CategoryWhat it doesPersonal data it receivesLocation
Cloud hosting providerRuns the servers for the platform and its databaseAll Customer Personal Data, stored on servers the Provider operatesUnited States
Backup storage providerHolds off-site copies of database backupsEncrypted files only; the provider cannot read themUnited States
GoogleHosts and sets up Google Workspace mailboxesMailbox users' names and email addresses, and the mailboxes themselvesUnited States and Google's global data centres
CloudflareDNS for domains connected for mailboxes; bot protection on formsDomain names and DNS records; visitors' IP address and browser signalsUnited States and Cloudflare's global network
Domain registrarRegisters and manages domain namesDomain names and their registrant, admin, tech and billing contactsEuropean Union
Phone number providerProvides rented numbers and receives their SMS and callsRented numbers; sender numbers, message text and call transcriptsHong Kong
Email delivery providerSends service emails (sign-up, receipts, alerts)Recipient email addresses and email contentUnited States
StripeCard payments for wallet top-upsThe reseller's billing contact and payment details (held by Stripe)United States
PostHogProduct analytics, only with consentUsage events and masked session replaysUnited States

Signature

For Enrich Labs LLC FZ: name, title, date (countersigned copies only).

Uses the Common Paper Data Processing Agreement Standard Terms Version 1.1, free to use under CC BY 4.0. This Cover Page is modified for ResellerHQ and is not itself a Common Paper standard.