Data Processing Addendum (DPA)
Last updated: September 27, 2026 · Standard contractual addendum governing personal data processing between J.E. Herizon LLC and Contractor Subscribers.
1. Scope and Relationship of the Parties
This Data Processing Addendum (“DPA”) supplements the JE Horizon Terms of Service entered into between J.E. Herizon LLC, a North Carolina limited liability company doing business as JE Horizon (“JE Horizon,” “Processor,” or “Service Provider”), and the subscribing contractor business entity (“Contractor,” “Customer,” or “Controller”).
Under applicable data protection laws: Contractor acts as the Data Controller, determining business purposes and means of customer communications. JE Horizon acts as the Data Processor, processing personal data strictly on behalf of Contractor and in accordance with Contractor’s instructions.
2. Details and Nature of the Processing
- Subject Matter: Provision of the contractor desk and, only after approval and activation, any automated receptionist, missed-call qualification, customer SMS text-back, and appointment features.
- Categories of Data Subjects: Contractor’s customers, prospective leads, and callers contacting Contractor’s designated business phone line.
- Types of Personal Data: Caller phone numbers, names, service addresses, voice recordings, voicemail transcripts, SMS conversation text, job problem summaries, and appointment timestamps.
- No Generalized Model Training: Processor shall not use Controller’s personal data or communications content to train generalized public artificial intelligence models.
3. Technical and Organizational Security Measures (GDPR Art. 32)
- Encryption in Transit: All public web traffic, API interactions, and telemetry utilize modern transport security (TLS 1.2+ mandatory).
- Encryption at Rest: Persistent database volumes and file storage repositories employ industry-standard encryption at rest (AES-256).
- Multi-Tenant Boundary Isolation: Contractor account data, customer records, and communication histories are strictly partitioned by unique tenant identifiers. Cross-tenant access is prohibited.
- Access Controls: Administrative access to production database clusters is restricted to authorized personnel via authenticated, audited credentials.
4. Subprocessor Management & Notification
Controller provides general authorization for Processor to engage infrastructure, telephony, and software subprocessors necessary to deliver the Services, including Fly.io (encrypted database & app hosting), Stripe (PCI-DSS Level 1 billing), Telnyx (carrier gateways & 10DLC routing), AWS (transactional email & storage), and Cloudflare (DDoS mitigation & SSL edge termination).
5. Data Subject Rights & Erasure
Controller may export customer records, conversation histories, and invoice data in structured formats directly from the dashboard. Inbound opt-out keywords (STOP, CANCEL, QUIT, UNSUBSCRIBE) are processed immediately by our telephony suppression engine, silencing further automated SMS.
6. Security Incident & Breach Notification
Processor shall notify Controller without unreasonable delay—and in any event within forty-eight (48) hours—after confirming a Personal Data Breach affecting personal data processed on Contractor’s behalf.
7. Return, Export, and Deletion of Data
Upon termination or expiration of Contractor’s subscription, Processor shall permanently delete all personal data residing in production database stores within thirty (30) days of subscription termination, subject only to operational backups retained up to ninety (90) days or legal hold obligations.
8. Contact
J.E. Herizon LLC (DBA JE Horizon) · Attn: Data Compliance Officer · 1930 Club Pond Rd #1061, Raeford, NC 28376, USA · [email protected]