Addendum
Data Processing Addendum
This addendum forms part of the Terms of Service between Leopard Manufacturing and the Agency. It governs Leopard's processing of personal data on the Agency's behalf, and takes precedence over the Terms on that subject.
Contents
1Definitions
Data Protection Law means every privacy and data protection law that applies to the processing, including the California Consumer Privacy Act as amended by the CPRA, other US state comprehensive privacy laws, and the UK and EU GDPR where applicable.
Personal Data means information within Agency Data that identifies or relates to an identifiable individual. Controller, Processor, Business, Service Provider, Data Subject, Consumer, Process and Personal Data Breach carry the meanings given by Data Protection Law. Other capitalised terms carry the meanings given in the Terms of Service.
2Roles
The Agency is the Controller and Business. Leopard is the Processor and Service Provider. Leopard processes Personal Data only on the Agency's documented instructions, which consist of the Terms of Service, this addendum, and the Agency's use of the features of the Service.
If Leopard believes an instruction infringes Data Protection Law, it will tell the Agency and may pause the affected processing.
3Scope of processing
| Subject matter | Providing the Leopard Dispatch service. |
|---|---|
| Duration | The term of the agreement, plus the 30-day post-termination window in section 13. |
| Nature and purpose | Hosting, storing, transmitting, displaying and backing up Agency Data so that the Agency can dispatch and record non-emergency calls, manage its members, and see unit positions and coverage. |
| Categories of Data Subject | The Agency's members (dispatchers, field units, supervisors, administrators), and members of the public recorded on a call. |
| Categories of Personal Data | Identifiers (name, callsign, badge number, sign-in identifier); authentication data (password hash, setup code hash); employment-context data (roles, duty status, shifts); precise geolocation (current position only); operational records (calls, assignments, event history, notes); vehicle data (licence plate and region, description); data about people recorded on calls (name, contact, notes); device data (push token or endpoint, user-agent). The full field list is published in the Privacy Policy. |
| Sensitive data | Precise geolocation is treated as sensitive personal information under California law. The Service collects no other category of sensitive data, and the Agency must not enter any into free-text fields. |
4Our obligations
Leopard will:
- process Personal Data only on the Agency's documented instructions, and not for its own purposes;
- not sell or share Personal Data, as those terms are defined in California law;
- not retain, use or disclose Personal Data outside the direct business relationship with the Agency, or for any purpose other than performing the Service;
- not combine Personal Data with data from other sources, except as permitted for a service provider under Data Protection Law;
- not use Personal Data to train machine-learning or artificial-intelligence models;
- ensure that personnel authorised to process Personal Data are bound by confidentiality;
- implement and maintain the security measures described in section 8;
- assist the Agency, taking account of the nature of processing, with data subject requests, security, breach notification and data protection impact assessments;
- tell the Agency if it can no longer meet its obligations under this addendum.
5California-specific terms
Leopard is a Service Provider. Personal Data is disclosed to Leopard only for the limited and specified business purpose of providing the Service. Leopard certifies that it understands the restrictions in section 4 and will comply with them.
The Agency may take reasonable and appropriate steps to ensure Leopard uses Personal Data consistently with the Agency's obligations, and, on notice of unauthorised use, may take reasonable steps to stop and remediate it.
6Your obligations
The Agency warrants that:
- it has a lawful basis for the Personal Data it puts into the Service, and for having Leopard process it;
- it has given every notice and obtained every consent that Data Protection Law requires — including, where required, written notice to members before their location is recorded, and any limits on tracking to working hours;
- its instructions will not put Leopard in breach of Data Protection Law;
- it will not enter into the Service any special category or sensitive data beyond the geolocation described in section 3, and in particular no government identifiers, financial account numbers, health information or biometric data.
7Subprocessors
The Agency gives general authorisation for Leopard to engage the subprocessors below. Each is bound by written terms no less protective than this addendum, and Leopard remains fully liable for their performance.
| Subprocessor | Purpose | Location |
|---|---|---|
| Supabase Inc. | Database, authentication, realtime messaging, backups | United States |
| Hostinger International Ltd. | Static web hosting; outbound transactional email | United States / EU |
| Browser and mobile push services (Apple, Google, Mozilla, Microsoft, as applicable to the member's device) | Delivering notifications to a member's device | United States |
Map tile, routing and address-lookup providers receive map coordinates and search text from the member's browser or app. They do not receive names, callsigns, call notes or details of people recorded on calls, and they do not process Personal Data on Leopard's behalf. Current providers are named in the Privacy Policy.
Changes. Leopard will give the Agency at least 30 days' notice before adding or replacing a subprocessor, by email to the account owner. If the Agency reasonably objects on data protection grounds within that period, the parties will discuss it in good faith; if it cannot be resolved, the Agency may terminate the affected part of the Service and receive a refund of prepaid unused fees.
8Security
Leopard maintains technical and organisational measures appropriate to the risk, including:
- Tenant isolation enforced in the database. Every record carries the agency it belongs to, and row-level security policies verify it on every read and write, so isolation does not depend on application code being correct.
- Authorisation enforced in the database. Rules about who may act on whom run as database triggers, so they apply to every access path rather than only to the user interface.
- Credentials. Passwords are stored only as one-way hashes. No Leopard personnel and no agency administrator can read, set or recover a member's password. Resets use a single-use code that expires in 30 minutes.
- Encryption in transit (TLS) for all connections and at rest for stored data.
- Access control. Access to production systems is limited to personnel who need it, and is authenticated individually.
- Rate limiting on authentication, with sign-in failures worded so they cannot be used to enumerate accounts.
- Backups taken by the database provider, encrypted, with defined retention.
- Logging of authentication events and of operational actions within an agency's account.
Leopard may change these measures provided the level of protection is not reduced.
9Personal data breaches
Leopard will notify the Agency without undue delay, and in any case within 72 hours, after becoming aware of a Personal Data Breach affecting the Agency's Personal Data. The notification will describe what is known of the nature of the breach, the categories and approximate number of records affected, the likely consequences, the measures taken or proposed, and a contact point.
Leopard will provide reasonable assistance to the Agency in meeting its own notification obligations to regulators and individuals. Notification is not an acknowledgement of fault.
10Individual rights
The Service gives the Agency the ability to access, correct, export and delete Personal Data within its own account, which in most cases lets the Agency answer a request without involving Leopard.
Where a request cannot be satisfied through the Service, Leopard will provide reasonable assistance. If an individual contacts Leopard directly about data in an Agency's account, Leopard will not respond substantively but will refer them to the Agency and tell the Agency promptly.
11Audits and assurance
Leopard will make available the information reasonably necessary to demonstrate compliance with this addendum, and will respond to a reasonable security questionnaire no more than once a year.
Where the Agency has a specific, documented regulatory requirement for an audit that cannot be met by that information, the parties will agree a scope, timing and mutually acceptable auditor in advance. Audits are at the Agency's expense, during business hours, no more than once in any twelve months unless required by a regulator or following a Personal Data Breach, and must not compromise the confidentiality or security of other agencies' data.
12Transfers
Personal Data is processed in the United States. Where Personal Data is transferred from the UK, the EEA or Switzerland, the parties will put in place an appropriate transfer mechanism, including the Standard Contractual Clauses and the UK Addendum where applicable, which are incorporated by reference with Leopard as data importer and the Agency as data exporter, and with the details in section 3 completing their annexes.
13Deletion and return
On termination the Agency may export its Personal Data through the Service for 30 days. After that period Leopard will delete it from live systems, and from backups as those backups expire in the ordinary cycle, except where law requires Leopard to keep it. Leopard will confirm deletion in writing if asked.
14Liability and term
Each party's liability under this addendum is subject to the limits in section 12 of the Terms of Service. This addendum takes effect when the Agency accepts the Terms of Service and continues for as long as Leopard processes Personal Data on the Agency's behalf.
An agency that requires a countersigned copy of this addendum for its procurement file may request one at contact@leopardmfg.com.