Data Processing Agreement
Last updated: Placeholder — not yet in effect
1. Parties
[Placeholder] This Data Processing Agreement ("DPA") is between Crankshaft ("Data Processor") and the customer ("Data Controller") who has agreed to the Crankshaft Terms of Service.
2. Scope of Processing
[Placeholder] Crankshaft processes personal data on behalf of the customer solely to provide the live transfer platform services described in the Terms of Service. Categories of data processed include:
- Consumer contact information (name, phone number)
- Consumer insurance intent signals and verbal responses
- Call recordings and transcripts
- Agent account and licensing data
3. Processor Obligations
[Placeholder] Crankshaft as Data Processor shall:
- Process personal data only on documented instructions from the controller
- Ensure persons authorized to process personal data are subject to confidentiality obligations
- Implement appropriate technical and organizational security measures
- Assist the controller in responding to data subject rights requests
- Delete or return personal data upon termination of services
- Provide information necessary to demonstrate compliance
4. Sub-processors
[Placeholder] Crankshaft uses the following sub-processors in the delivery of services:
- Supabase — database hosting (USA)
- Google Cloud — infrastructure (USA)
- Stripe — payment processing (USA)
- Resend — transactional email (USA)
- Attio — CRM (USA)
- PostHog — product analytics (USA / EU)
- [AI/LLM provider] — call screening AI (TBD)
5. Security Measures
[Placeholder] Crankshaft implements the following security measures:
- Encryption of data in transit (TLS 1.2+)
- Encryption of data at rest (AES-256)
- Role-based access controls
- Regular security assessments
- Incident response procedures
6. Data Breach Notification
[Placeholder] In the event of a personal data breach, Crankshaft shall notify the affected customer without undue delay and no later than 72 hours after becoming aware, to the extent feasible.
7. International Transfers
[Placeholder] Data is primarily processed in the United States. Crankshaft will ensure any cross-border data transfers are made subject to appropriate safeguards.
8. Contact
DPA inquiries: privacy@crankshaft.ai