Data Processing Addendum

Terms such as “personal data”, “processing”, “controller”, “processor”, “data subject”, and “personal data breach” have the meanings given in applicable data protection law, including the EU/UK GDPR, India’s Digital Personal Data Protection Act, 2023 (“DPDP”), and the California Consumer Privacy Act (“CCPA”). “Data Fiduciary” and “Data Processor” carry their DPDP meanings.

For visitor data the customer collects through the Service, the customer is the Controller / Data Fiduciary and Entrifie is the Processor / Data Processor, acting only on the customer’s documented instructions. For data Entrifie collects about the customer’s own account and website use, Entrifie is the Controller, governed by its Privacy Policy.

• Subject matter: provision of the visitor-management Service.
• Duration: the term of the agreement, plus the retention period the customer configures.
• Nature and purpose: registering visitors, issuing passes, notifying hosts, and maintaining an access audit log.
• Categories of data subject: the customer’s visitors, hosts, and authorised personnel.
• Categories of personal data: names, contact details, company, host, visit purpose, timestamps, vehicle number (where enabled), and visitor photos (where enabled and consented).

Entrifie will process personal data only on the customer’s documented instructions (including as set out in the agreement and this Addendum), unless required otherwise by law, in which case Entrifie will inform the customer first where legally permitted. Entrifie will promptly notify the customer if, in its opinion, an instruction infringes applicable data protection law.

Entrifie ensures that personnel authorised to process personal data are bound by appropriate confidentiality obligations and access it only on a need-to-know basis.

Entrifie maintains technical and organisational measures appropriate to the risk, including:

• Encryption in transit (TLS) and at rest (AES-256).
• Data residency in India (asia-south1, Mumbai) for the primary datastore.
• Role-based access control and tenant isolation enforced at the database-rule layer.
• Authentication via managed identity providers; no plaintext passwords.
• Automated, retention-bound deletion of visitor records and photos.
• Audit logging of administrative and data-subject-request actions.

The customer authorises Entrifie to engage the sub-processors below. Entrifie imposes data protection obligations on each that are no less protective than this Addendum, and remains responsible for their performance. Entrifie will give notice of any intended addition or replacement, allowing the customer a reasonable period to object.

The current list is also maintained at entrifie.com/legal/sub-processors.

Taking into account the nature of the processing, Entrifie assists the customer with appropriate technical and organisational measures to respond to data-subject requests (access, correction, erasure, and consent withdrawal), including through the in-product Data Requests tools. If Entrifie receives a request directly from a data subject, it will refer them to the relevant customer or to entrifie.com/privacy/dsr where appropriate.

Entrifie will notify the customer without undue delay after becoming aware of a personal data breach affecting the customer’s data, and will provide information reasonably required for the customer to meet its own notification obligations (e.g. to the Data Protection Board of India or a supervisory authority).

Entrifie provides reasonable assistance to the customer with data protection impact assessments and prior consultations with supervisory authorities, taking into account the nature of the processing and the information available to Entrifie.

The primary datastore is located in India. Where a sub-processor processes personal data outside the customer’s jurisdiction, such transfers are made under an appropriate transfer mechanism (for example, Standard Contractual Clauses or an adequacy decision) as required by applicable law.

Entrifie makes available information reasonably necessary to demonstrate compliance with this Addendum and allows for and contributes to audits, including inspections, conducted by the customer or an auditor it mandates, on reasonable prior notice, subject to confidentiality and without compromising other customers’ data.

On termination of the Service, and at the customer’s choice, Entrifie deletes or returns the personal data it processes on the customer’s behalf and deletes existing copies, unless retention is required by law. Routine retention-bound deletion continues to apply throughout the term.

Each party’s liability under this Addendum is subject to the limitations and exclusions of liability set out in the agreement.

This Addendum takes effect on the customer’s acceptance and remains in force for as long as Entrifie processes personal data on the customer’s behalf under the agreement.

This Addendum is governed by the law specified in the agreement and, in the absence of such a choice, by the laws of India.