Nestora Data Processing Addendum

Purpose

This Data Processing Addendum ("DPA") applies when Ingress Technology LLC processes personal information or Customer Data on behalf of a homeowners association, condominium association, residential community, property owner, or property management company using Nestora.

Roles

Customer is the data owner, controller, or business that determines the purposes and means of processing Customer Data. Ingress Technology acts as a service provider, processor, or similar role by processing Customer Data solely to provide, maintain, secure, and support Nestora.

Processing Instructions

Ingress Technology shall process Customer Data only according to Customer's documented instructions, the applicable agreement, this DPA, and applicable law.

Dedicated Environment

Customer Data is maintained within Customer's dedicated Nestora environment and logically separated from data belonging to other customers.

No Sale or Commercialization

Ingress Technology shall not sell, rent, disclose, mine, profile, or otherwise commercialize Customer Data. Ingress Technology shall not use Customer Data to provide services to another customer.

Security Measures

Ingress Technology maintains commercially reasonable safeguards including encrypted communications, access controls, authentication controls, administrative access limitations, backup procedures, and monitoring designed to protect Customer Data.

Subprocessors

Ingress Technology may use subprocessors to host, operate, secure, support, or improve the Services. Subprocessors may process Customer Data only as necessary to support the Services and must be subject to appropriate confidentiality and data protection obligations.

Privacy Requests

Customer is responsible for receiving and responding to privacy requests from residents, homeowners, tenants, guests, visitors, and other individuals. Ingress Technology shall reasonably assist Customer in responding to such requests where required by law or contract.

Data Export and Deletion

Upon Customer's request after termination, Ingress Technology shall make Customer Data available for export in a commercially reasonable electronic format and shall delete Customer Data according to the applicable agreement, unless retention is required by law.

Confidentiality

Ingress Technology shall ensure personnel with access to Customer Data are subject to appropriate confidentiality obligations.

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