Data Processing Addendum

Instructions and scope

This DPA supplements the customer agreement when Clear Treasury processes personal data on the customer’s behalf. The subject matter is provision of transportation revenue-control software and assisted services; duration is the agreement term plus the deletion period; data subjects may include customer personnel, contractors, drivers, carrier contacts, and business counterparties; data types are those submitted or generated for the service.

Processor duties

• Process personal data only on documented customer instructions, including the agreement and product configuration, unless law requires otherwise.
• Ensure authorized personnel are bound by confidentiality obligations.
• Maintain reasonable security controls and notify the customer without undue delay after confirming a personal-data breach affecting Customer Personal Data.
• Provide reasonable assistance with data-subject requests, security inquiries, impact assessments, and regulator consultation, taking into account the nature of processing.
• Delete or return Customer Personal Data at the end of service in accordance with the retention schedule, unless law requires retention.

Subprocessors and transfers

The customer gives general authorization for the listed subprocessors. Clear Treasury remains responsible for their processing to the extent required by applicable data-protection law and uses contractual transfer safeguards where required. The customer may object to a new material subprocessor on reasonable data-protection grounds.

Audit information

On reasonable written request, Clear Treasury will provide available information needed to demonstrate these obligations. Any additional audit must be proportionate, protect other customers and confidential systems, occur no more than once annually unless an incident or regulator requires otherwise, and be at the requesting customer’s expense unless material noncompliance is found.

Execution

This posted DPA is a baseline form and becomes binding only when incorporated into a signed order, agreement, or countersigned DPA. Request a signature copy at legal@cleartreasury.ai.