Legal
Data Processing Addendum
Jump to a section
- 1. What this addendum is
- 2. Words we use
- 3. What we process, and why
- 4. Your instructions
- 5. Confidentiality
- 6. Security
- 7. Sub-processors
- 8. Transfers outside the UK
- 9. Helping you meet your obligations
- 10. When the Service ends
- 11. Showing we comply
- 12. Where Reyse is the controller
- 13. Liability, changes and law
1. What this addendum is
This Data Processing Addendum is part of the agreement between you, the client, and Reyse under our Terms of Service (clause 8). It applies whenever we process personal data on your behalf to provide the Service. For that personal data, you are the controller and we are your processor, as those terms are defined in UK GDPR. If this addendum and the Terms disagree about personal data we process for you, this addendum wins.
Reyse is being registered as a limited company. Until registration completes, Reyse is operated by Morgan King, contactable at hello@reyse.co.uk. The company's legal name, company number and registered office will appear here as soon as registration completes.
2. Words we use
"UK GDPR" means the UK General Data Protection Regulation, read with the Data Protection Act 2018, as amended. "Client Personal Data" means the personal data we process for you to provide the Service. "Sub-processor" means another business we use that processes Client Personal Data. "Personal data breach" has the meaning in UK GDPR. Other terms, such as controller, processor and data subject, have their UK GDPR meanings.
3. What we process, and why
- Subject matter and duration: providing the Service to you, for as long as our agreement lasts and the short time afterwards described in clause 10.
- Nature and purpose: asking your customers for reviews and following up; drafting replies to reviews for you to approve; counting and attributing your enquiries through your tracked phone number and website forms; preparing your reports; and keeping your listings and website details accurate.
- Types of personal data: names, email addresses and phone numbers of your customers whom you ask us to contact for reviews, with whether it was a sale or a let; reviewers' names and what they wrote; callers' phone numbers, call times and durations through your tracked number (and recordings only if you ask for them in writing); details people send through your tracked website forms; and your team's names, roles and work contact details.
- Data subjects: your customers and prospective customers (sellers, buyers, landlords and tenants), people who review you, call you or enquire through your website, and your staff.
- Special category data: we don't need it. Please don't send us health, financial-hardship or other special category data about your customers; if any reaches us by accident, we delete it.
4. Your instructions
We process Client Personal Data only on your documented instructions. Those instructions are this agreement, your order, your take-on form and anything further you tell us in writing, including by email. We tell you straight away if we think an instruction breaks data protection law. If the law requires us to process Client Personal Data in another way, we tell you first, unless the law forbids that. You're responsible for having a lawful basis for the processing you ask us to do, for giving your customers the privacy information they need (for example, that you may ask them for a review), and for the accuracy of what you send us.
5. Confidentiality
Everyone at Reyse, and anyone working for us, who can access Client Personal Data is bound to keep it confidential and uses it only to provide the Service.
6. Security
We take technical and organisational measures appropriate to the risk, as Article 32 of UK GDPR requires. They include:
- access to your systems by invitation only, at the least level that does the job, and never by sharing your passwords;
- two-step sign-in on the accounts we use to hold or reach Client Personal Data;
- encryption in transit (HTTPS) and, through our hosting providers, at rest;
- access to Client Personal Data limited to the people who need it to provide the Service;
- keeping only what the Service needs, and deleting it on the schedule in clause 10.
We review these measures as the Service and the risks change.
7. Sub-processors
You give us general permission to use sub-processors. These are the ones we use now, for the parts of the Service you have:
- Supabase Inc.: hosts the database that holds Client Personal Data.
- Cloudflare, Inc.: runs the service that processes it (reviews, enquiries and reports).
- Vercel Inc.: hosts reyse.co.uk, including your private report and approval pages.
- Google LLC (Google Workspace): our email, for messages with you and, where you ask us to, with your customers.
- Resend, Inc.: sends the review request emails to your customers in your name.
- OpenAI, L.L.C.: helps draft review replies, which a person checks before anything is posted.
- Anthropic PBC: helps prepare your monthly work and reports.
- Our call tracking provider, when we set up your tracked number, and our text message provider, before we first send review requests by text: we name each one here before first use, with the notice below.
We tell you in writing at least 14 days before we add or replace a sub-processor. You can object on reasonable data protection grounds within that time. If we can't resolve your objection, you can end the affected part of the Service without any penalty. We put the same data protection obligations on each sub-processor by contract, and we remain responsible to you for what they do.
8. Transfers outside the UK
Some sub-processors are based in, or process data in, the United States. We transfer Client Personal Data outside the UK only with a safeguard recognised under UK GDPR: typically the UK-US Data Bridge where the provider is certified under it, or the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses, where it isn't. You can ask which safeguard applies to any provider.
9. Helping you meet your obligations
- Data subject requests: if someone asks us directly to see, correct or delete their data, or objects, we pass it to you within 3 working days and don't answer it ourselves unless you ask us to. We help you answer requests, so far as our part of the processing allows.
- Personal data breaches: we tell you without undue delay, and within 48 hours of becoming aware of a breach affecting Client Personal Data, with what we know about its nature, the data and people involved, the likely consequences and what we're doing about it, adding detail as we learn it. We help you decide whether to report it to the ICO and tell the people affected.
- Assessments: we give you reasonable help with data protection impact assessments and any prior consultation with the ICO, for the processing we do for you.
10. When the Service ends
Within 30 days of our agreement ending, we delete Client Personal Data, or return it to you first if you ask in writing before then, unless the law requires us to keep it. Copies in our providers' backups are overwritten in their normal cycle and are not used in the meantime. Our own records of the agreement, such as your acceptance of these terms and your invoices, are ours as controller and are kept as the law requires.
11. Showing we comply
We give you the information you reasonably need to show that we meet these obligations. We allow, and contribute to, audits and inspections by you or an auditor you appoint who is bound by confidentiality, on at least 30 days' written notice, during working hours, no more than once a year unless there's been a personal data breach or the ICO requires it. We may first answer by written questionnaire, and each party bears its own costs.
12. Where Reyse is the controller
Some personal data we hold, such as your team's work contact details for running your account, and the business contact details we hold about agencies, is ours as controller. Our Privacy Policy covers it, not this addendum.
13. Liability, changes and law
Each party's liability under this addendum is subject to the limits in clause 13 of the Terms of Service, except where the law doesn't allow it to be limited. We may update this addendum to reflect changes in the law, guidance or the Service; if a change is material, we tell you in advance as clause 17 of the Terms says. This addendum is governed by the laws of England and Wales. Questions about it go to hello@reyse.co.uk.