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Data processing agreement

Last updated 12 September 2026. Forms part of the terms of service between Chinmoy Goswami, trading as Viewbook ("processor", "Viewbook") and the client ("controller"). Drafted for UK GDPR, EU GDPR and the UAE PDPL.

1. Subject matter and duration

Processing of buyer and client personal data needed to run the WhatsApp assistant, portal-lead intake, bookings, buyer pages and reports, for as long as the client subscribes plus the 30-day export window.

2. Nature and purpose

Receiving, storing and answering buyer messages; creating leads and bookings; sending reminders; storing documents buyers choose to send; producing dashboards and reports for the client; where the client enables it, answering buyers' own AI assistants through a structured interface and holding their viewing requests until the buyer confirms; measuring which parts of buyer pages and video tours are used, by opaque token; unless the client switches it off, deriving de-identified conversation patterns (question type, assistant action, outcome; no names, numbers, prices, places or listings) into a shared store used to improve reply quality across clients.

3. Data and data subjects

Buyers and prospective buyers: phone number, name, message content, stated budget, area, timeline, financing status, documents they send (for example proof of funds), bookings. Client staff: names, WhatsApp numbers, emails, calendar availability.

4. Processor obligations

  • Process personal data only on the client's documented instructions, which are these terms and the client's dashboard settings.
  • Keep staff and contractors under confidentiality.
  • Apply the security measures in section 6.
  • Assist the client with data-subject requests, impact assessments and regulator enquiries; the dashboard lets the client delete a buyer's data itself.
  • Delete or return all personal data at the end of the service, within 30 days, and delete backups within 14 days after that.
  • Make available the information needed to demonstrate compliance and allow audits on reasonable notice, at most once a year unless a regulator requires otherwise.

5. Sub-processors

The client authorises these sub-processors: Anthropic (AI model), Meta Platforms and Twilio (WhatsApp delivery), Google (maps, geocoding, commute times), Voyage AI (document search, if enabled), Resend (email), Polar (payments), Hetzner (hosting, Finland), Cloudflare (encrypted offsite backup copies, EU jurisdiction). Viewbook gives 14 days' notice by email before adding or replacing one; the client may object, and if the objection cannot be resolved, terminate without penalty.

6. Security

Encrypted transport (TLS) everywhere; webhook signature verification; per-client data isolation; hashed passwords, optional or client-required two-factor sign-in, owner and member roles, login throttling and a sign-in log; server firewall; data and backups in an encrypted volume on the server; daily backups kept 14 days on EU servers with an encrypted offsite copy; tested restores; health monitoring and alerts; document audiences so nothing reaches a public page unless the client marks it; buyer conversations are not used to train AI models. Statements about sub-processors' contractual terms are to be confirmed against the provider accounts in force at signature.

7. International transfers

Data is hosted in the EU. Sub-processors in the United States (Anthropic, Meta, Twilio, Google, Voyage, Resend, Polar) are engaged under the EU Standard Contractual Clauses and the UK International Data Transfer Addendum, or the EU-US Data Privacy Framework where the sub-processor is certified.

8. Personal data breach

Viewbook notifies the client without undue delay and within 72 hours of becoming aware of a breach affecting the client's data, with what is known at that point and updates as the investigation proceeds.

9. Liability

Each party is liable for its own breaches of data protection law; the liability caps in the terms of service apply to this agreement.

10. Signing

This agreement is accepted when the client accepts the terms of service. A countersigned copy on the client's paper is available on request.

© Chinmoy Goswami, trading as Viewbook · PrivacyTermsData processing agreement
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