PARTIES AND EXECUTION 

Entity details:  

ItBox LTD 

Company number: 15638477 

Registered office address: 24 Old Bond Street, London, United Kingdom, W1S 4AP 

 

(referred to as “ItBox” in the Main Agreement and “ItBox” or “Processor” in this DPA). 

  

Entity details:  

The “Customer” as set out in the Main Agreement. 

(referred to as “Customer” in the Main Agreement and “Customer” or “Controller” in this DPA). 

Signature: 

Signed in accordance with the Main Agreement. 

Signature: 

Signed in accordance with the Main Agreement. 

Name: 

Name: 

Title: 

Title: 

Date: 

Date: 

 

 

VARIABLES 

Parties’ relationship 

Controller to Processor 

Parties’ roles 

Customer will act as the Controller (as defined in Section 1 of the Terms) 

ItBox will act as the Processor (as defined in Section 1 of the Terms) 

Contacts 

Controller 

Processor 

Name: 

Email: 

As set out in the Main Agreement. 

Name: 

Email: 

As set out in the Main Agreement. 

Main Agreement 

The Agreement entered into between ItBox and the Customer in relation to the provision of the Services under the Main Agreement.  

Term 

This DPA will commence on the Effective Date as set out in the Main Agreement and will continue for the Subscription Term as set out in the Main Agreement. 

Breach Notification Period 

Without undue delay and no later than 72 hours after becoming aware of a personal data breach. 

Sub-processor Notification Period 

​​A reasonable timeframe before the new sub-processor is granted access to Personal Data.  

Liability Cap 

Each party’s aggregate liability under this DPA will not exceed the liability caps as per the Main Agreement. 

Governing Law and Jurisdiction 

As per the Main Agreement. 

Data Protection Laws 

All laws, regulations and court orders which apply to the processing of Personal Data in the United Kingdom (UK). 

This includes UK GDPR and the Data Protection Act 2018 each as amended from time to time. 

Services related to processing 

As described in the Main Agreement. 

Duration of processing 

For the Term of this DPA. 

Nature and purpose of processing 

Collection, storage and deletion for the purposes of providing the Services under the Main Agreement. 

Personal Data 

The types of Personal Data processed are: 

Landlords 

  • Identity Data: first name, last name 

  • Contact Data: home address, email address and telephone number 

 

Tenants/Residents 

  • Identity Data: first name, last name 

  • Contact Data: home address, email address and telephone number 

  • Usage Data: includes information about how Tenants/Residents interact with and use ItBox’s app including audit logs and consent and engagement records 

  • Profile Data: includes username and password, tenant status, languages spoken, preferences, feedback and survey responses, complaints and issue logs, consultation records 

  • Special Category Data: includes health data relating to the ability to walk and hear 

 

Property Managers 

  • Identity Data: first name, last name, job title 

  • Contact Data: business email address 

 

Principle Accountable Persons 

  • Identity Data: first name, last name, job title 

  • Contact Data: email address 

 

Data subjects 

The individuals whose Personal Data will be processed are: 

  • Landlords 

  • Tenants/Residents 

  • Managing Agents 

  • Principal Accountable Persons 

 

Special provisions 

None. 

​​Transfer Mechanism  

N/A 

 

 

ANNEX 1 

Security measures. Technical and organisational measures to ensure the security of Personal Data 

Technical Security Measures 

  • Data encryption: Securing personal data both in transit and at rest. 

  • Secure user authentication: Ensuring encrypted credentials and identity management. 

  • Regular backups: Perform automated backups and store them securely with disaster recovery procedures. 

Organisational Security Measures 

  • Data protection policies: Implement and maintain documented data protection and security policies. 

  • Access control & role-based access: Restrict access to personal data based on need-to-know principles (e.g., employees, contractors). 

  • Data centre security: Ensure server rooms & data centres have restricted access, surveillance, and authentication controls. 

 

 

ANNEX 2 

Sub-processors. Current sub-processors  

  • Google (for infrastructure/hosting) -- all Personal Data processed in the UK. 

 

 

 

TERMS 

 

  1. What is this agreement about? 

 

  1. Purpose. The parties are entering into this Data Processing Agreement (DPA) for the purpose of processing Personal Data (as defined above). 

  1. Definitions. Under this DPA:  

  1. adequate country means a country or territory that is recognised under Data Protection Laws from time to time as providing adequate protection for processing Personal Data, and 

  1. Controller, data subject, personal data breach, process/processing, Processor and supervisory authority have the same meanings as in the Data Protection Laws, and 

  1. Sub-Processor means another processor engaged by the Processor to carry out specific processing activities with Personal Data. 

 

 

 

  1. What are each party’s obligations? 

 

  1. ​​Controller obligations. Controller instructs Processor to process Personal Data in accordance with this DPA, and is responsible for providing all notices and obtaining all consents, licences and legal bases required to allow Processor to process Personal Data. 

  1. Processor obligations. Processor will: 

  1. only process Personal Data in accordance with this DPA and Controller’s instructions (unless legally required to do otherwise), 

  1. not sell, retain or use any Personal Data for any purpose other than as permitted by this DPA and the Main Agreement, 

  1. inform Controller immediately if (in its opinion) any instructions infringe Data Protection Laws, 

  1. use the technical and organisational measures described in Annex 1 when processing Personal Data to ensure a level of security appropriate to the risk involved, 

  1. notify Controller of a personal data breach within the Breach Notification Period and provide assistance to Controller as required under Data Protection Laws in responding to it, 

  1. ensure that anyone authorised to process Personal Data is committed to confidentiality obligations, 

  1. without undue delay, provide Controller with reasonable assistance with:  

  1. data protection impact assessments,  

  1. responses to data subjects’ requests to exercise their rights under Data Protection Laws, and  

  1. engagement with supervisory authorities,  

  1. if requested, provide Controller with information necessary to demonstrate its compliance with obligations under Data Protection Laws and this DPA, 

  1. allow for audits at Controller’s reasonable request, provided that audits are limited to once a year and during business hours except in the event of a personal data breach, and 

  1. return Personal Data upon Processor’s written request or delete Personal Data by the end of the Term, unless retention is legally required.   

  1. Warranties. The parties warrant that they and any staff and/or subcontractors will comply with their respective obligations under Data Protection Laws for the Term. 

 

  1. Sub-processing 

 

  1. Use of sub-processors. Controller authorises Processor to engage other processors (referred to in this section as sub-processors) when processing Personal Data. Processor’s existing sub-processors are listed in Annex 2. 

  1. Sub-processor requirements. Processor will:  

  1. require its sub-processors to comply with equivalent terms as Processor’s obligations in this DPA, 

  1. ensure appropriate safeguards are in place before internationally transferring Personal Data to its sub-processor, and 

  1. be liable for any acts, errors or omissions of its sub-processors as if they were a party to this DPA. 

  1. Approvals. Processor may appoint new sub-processors provided that they notify Controller in writing in accordance with the Sub-processor Notification Period.  

  1. Objections. Controller may reasonably object in writing to any future sub-processor. If the parties cannot agree on a solution within a reasonable time, either party may terminate this DPA. 

 

  1. International personal data transfers 

 

  1. Instructions. Processor will transfer Personal Data outside the UK, the EEA or an adequate country only on documented instructions from Controller, unless otherwise required by law. 

  1. Transfer mechanism. Where a party is located outside the UK, the EEA or an adequate country and receives Personal Data:  

  1. that party will act as the data importer, 

  1. the other party is the data exporter, and 

  1. the relevant Transfer Mechanism will apply. 

  1. Additional measures. If the Transfer Mechanism is insufficient to safeguard the transferred Personal Data, the data importer will promptly implement supplementary measures to ensure Personal Data is protected to the same standard as required under Data Protection Laws. 

  1. Disclosures. Subject to terms of the relevant Transfer Mechanism, if the data importer receives a request from a public authority to access Personal Data, it will (if legally allowed): 

  1. challenge the request and promptly notify the data exporter about it, and 

  1. only disclose to the public authority the minimum amount of Personal Data required and keep a record of the disclosure.  

 

 

 

 

  1. Other important information 

 

  1. Survival. Any provision of this DPA which is intended to survive the Term will remain in full force. 

  1. Order of precedence. In case of a conflict between this DPA and other relevant agreements, they will take priority in this order:  

  1. Transfer Mechanism, 

  1. DPA, 

  1. Main Agreement. 

  1. Notices. Formal notices under this DPA must be in writing and sent to the Contact on the DPA’s front page as may be updated by a party to the other in writing. 

  1. Third parties. Except for affiliates, no one other than a party to this DPA has the right to enforce any of its terms. 

  1. Entire agreement. This DPA supersedes all prior discussions and agreements and constitutes the entire agreement between the parties with respect to its subject matter and neither party has relied on any statement or representation of any person in entering into this DPA. 

  1. Amendments. Any amendments to this DPA must be agreed in writing. 

  1. Assignment. Neither party can assign this DPA to anyone else without the other party's consent.  

  1. Waiver. If a party fails to enforce a right under this DPA, that is not a waiver of that right at any time. 

  1. Governing law and jurisdiction. The Governing Law applies to this DPA and all disputes will only be litigated in the courts of the Jurisdiction.