Data Processing Addendum

Last updated: 15 September 2025

This DPA applies when we process personal data on behalf of a business customer.

Parties

Controller: Customer identified in the Order. Processor: Irelco Ltd trading as FOCUSER, company number 15377065.

Subject matter and duration

Provision of the FOCUSER service for the term of the Agreement.

Nature and purpose of processing

Hosting, storage, retrieval, display, analytics, and support.

Categories of data subjects and data

Customer staff and end users. Identification data, account data, usage data, content entered by users.

Processor obligations

• Process only on documented instructions from Controller
• Keep data confidential and secure
• Assist with data subject rights and DPIAs where reasonable
• Engage sub processors only with notice and appropriate contracts
• Delete or return data at end of service
• Provide information to demonstrate compliance and allow audits with reasonable notice
• Notify Controller of personal data breaches without undue delay

International transfers

We will use appropriate safeguards for transfers outside the UK, such as the UK IDTA or EU SCCs.

Liability

Each party’s liability is as set out in the Agreement. Nothing limits liability where unlawful to do so.

Governing law: England and Wales.