WorkTwins Data Processing Addendum

1. Parties

This Data Processing Addendum (“DPA”) applies where WorkTwins processes personal data on behalf of a company customer.

2. Roles

The company customer is generally the controller or business for employee/candidate data it provides or directs WorkTwins to process.

WorkTwins may act as a processor or service provider for company-directed processing.

For direct individual user accounts, WorkTwins may act as an independent controller for its own service purposes.

Final roles must be confirmed in the applicable order form or agreement.

3. Subject Matter

WorkTwins processes personal data to provide WorkFootPrint, matching, collaboration, chat, administration, security, support, and billing features.

4. Duration

Processing continues for the term of the agreement and any legally required retention period.

5. Categories of Data

• account data;
• work-context derived signals;
• WorkFootPrint features;
• compatibility scores;
• collaboration data;
• chat data;
• company workspace data;
• support data;
• billing metadata.

6. Categories of Data Subjects

• individual users;
• employees;
• candidates;
• contractors;
• company administrators;
• support contacts.

7. Processor Obligations

WorkTwins will:

• process personal data only on documented instructions;
• maintain confidentiality;
• implement appropriate security measures;
• use subprocessors under appropriate agreements;
• assist with data subject requests;
• assist with DPIAs where required;
• notify of security incidents as required;
• delete or return data at termination, unless retention is required.

8. Subprocessors

WorkTwins may use subprocessors listed in the Subprocessors Page.

9. International Transfers

Where required, WorkTwins will use appropriate transfer mechanisms.

10. Audits

Audit rights and documentation access should be defined in the enterprise agreement.

11. Contact

Privacy/legal contact: [email protected]