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Data Processing Addendum
Last Updated: August 23, 2026
This Data Processing Addendum ("DPA") is entered into between Eternal Me Corporation ("Company") and the customer ("Customer") and is incorporated into and subject to the Universal Terms of Service and applicable service agreements (collectively, the "Agreements"). In the event of conflict, this DPA controls on data protection matters only.
- Roles. With respect to Personal Data processed on behalf of Customer in connection with the Products, Customer is the data controller and Company is the data processor. For data Company collects independently for its own purposes, Company acts as an independent controller governed by the Privacy Policy.
- Processing. Company shall process Personal Data only as necessary to provide the Products and as instructed by Customer through the Agreements, or as required by law.
- Confidentiality. Company shall ensure personnel with access to Personal Data are subject to confidentiality obligations.
- Security. Company shall implement commercially reasonable technical and organizational measures to protect Personal Data appropriate to the risk.
- Subprocessors. Customer authorizes Company to engage subprocessors as necessary to provide the Products. Company will maintain a current list of subprocessors at https://eternal.me/terms/subprocessors and will notify Customer of material changes. Customer may object to a new subprocessor within thirty (30) days of notice.
- Data Subject Rights. Company shall provide reasonable assistance to Customer in responding to data subject requests under applicable law, to the extent the data is within Company's control.
- Breach Notification. Company shall notify Customer within seventy-two (72) hours of becoming aware of a personal data breach affecting Customer's Personal Data, to the extent permitted by law.
- Deletion. Upon termination or written request, Company shall handle Personal Data in accordance with the data retention and disposal terms of the applicable service agreement, except where retention is required by law.
- Audit. Upon written request, Company shall provide information reasonably necessary to demonstrate compliance with this DPA, which may include completing a reasonable security questionnaire or providing available third-party certification reports. Physical audits require Company's prior written consent.
- International Transfers. Where required by applicable law, Company shall ensure appropriate safeguards are in place for any transfer of Personal Data across international borders. Additional provisions relating to data location, comparable protection, and cross-border transfers apply to Customers established in Canada, as set out in the Canada-Specific Terms at https://eternal.me/terms/canada.
- Liability. Each party's liability under this DPA is subject to the limitations in the Universal Terms of Service.
- Governing Law. This DPA is governed by the laws of the State of New York.
- Miscellaneous. Capitalized terms not defined herein have the meanings given in the Agreements. This DPA supersedes any prior data processing terms between the parties.
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