Data Processing Agreement
This DPA forms part of the agreement between SwiftChat (Processor) and the customer (Controller). It applies whenever SwiftChat processes personal data on the customer’s behalf.
1. Scope
This DPA governs SwiftChat's processing of personal data submitted by the Controller and end-customers via WhatsApp. It is incorporated by reference into the Terms of Service.
2. Roles
The Customer is the data Controller; SwiftChat is the Processor. End-customers' WhatsApp messages and contact information are processed on the Customer's instructions.
3. Subject matter and duration
Processing continues for the term of the subscription plus 90 days for safe deletion.
4. Nature and purpose
Storage, transmission, and analytics necessary to deliver the Service: shared inbox, broadcasts, templates, automations, AI features, and reporting.
5. Categories of data
- End-customer identifiers (phone, name, profile)
- Message content (text, media, metadata)
- Custom attributes you configure
- Operator (your team) identifiers and access logs
6. Subprocessors
We use the subprocessors listed at /security#subprocessors. The Controller authorises these subprocessors. We provide 30 days advance notice of changes.
7. International transfers
Where transfers leave the EU/EEA, we rely on Standard Contractual Clauses (Module 2 or 3). EU representatives are designated via Prighter.
8. Security
We maintain appropriate technical and organisational measures: TLS 1.3 in transit, AES-256 at rest, KMS-managed keys, audit log, role-based access, monitoring. See /security for details.
9. Breach notification
Without undue delay, and in any event within 72 hours of becoming aware of a personal data breach, we will notify the Controller with the information required under GDPR Article 33.
10. Audits
Customers may request our most recent SOC 2 / ISO attestations once available. On Enterprise plans, on-site audits may be arranged annually with reasonable notice.
11. Data subject rights
We assist the Controller with responding to data subject requests (access, erasure, restriction, portability, objection).
12. Deletion
At the end of processing, we delete personal data within 30 days unless retention is required by law.
13. Liability
The liability cap in the Terms of Service applies.
14. Contact
Use the contact form for DPA queries.