LightLink

Data Processing Agreement

Last updated May 9, 2026

This Data Processing Agreement ("DPA") supplements the LightLink Terms of Service and forms the agreed terms under which LightLink (the "Processor") processes personal data on behalf of the Customer (the "Controller") for purposes of the Service.

1. Definitions

Terms have the meanings given to them in the EU General Data Protection Regulation (GDPR) and analogous laws where applicable (UK GDPR, CCPA, PDP Bill).

2. Subject matter and duration

Subject matter: workforce-tracking and analytics services. Duration: for the term of the Customer's subscription, plus a 30-day data preservation window post-termination.

3. Nature and purpose

Processing is necessary to provide the Service contracted by the Controller, including: capturing activity data, generating reports, sending notifications, billing, and AI-assisted analytics where enabled.

4. Categories of data subjects

5. Categories of personal data

CategoryExamples
IdentificationName, employee ID, email, phone
EmploymentDepartment, designation, joining date
ActivityApp usage, URL domains, mouse/keyboard counts
VisualScreenshots (auto-blurred for sensitive apps when enabled)
TechnicalDevice hostname, OS, IP address, agent version
AuthenticationHashed passwords, OTP secrets, session tokens

6. Sub-processors

We use a small set of vetted sub-processors to deliver the Service:

Sub-processorPurposeRegion
AnthropicAI Assistant + anomaly detection (only when Customer enables)USA
RazorpayPayment processing for INR billingIndia
Let's EncryptTLS certificate issuanceUSA
WhatsAPI (whatsapi.live.pwtech.pw)WhatsApp delivery (when Customer enables alerts)India

We give 30 days' notice to the Customer admin email before adding or replacing a sub-processor.

7. Security measures

See the Security Practices page for details. Summary:

8. Data subject rights

We assist the Controller in responding to data-subject requests (access, rectification, erasure, portability, restriction, objection):

9. Personal-data breach notification

We notify the Controller's admin contact within 72 hours of confirming a breach affecting their data, with the information required by GDPR Art. 33(3).

10. Audit rights

Controllers may, at their cost and with reasonable notice, audit our processing once per year — typically by reviewing this DPA, the Security Practices page, and the audit log inside the admin panel. Onsite audits are available for Enterprise plans.

11. Returning or deleting data

On termination, we either return all data (JSON archive on request) or delete it within 30 days, per the Controller's instruction. Backups are purged within 90 days of the deletion.

12. International transfers

Where Personal Data is transferred outside the country of origin (e.g. to Anthropic in the USA for AI features), we rely on Standard Contractual Clauses or equivalent safeguards.

13. Liability

Each party's liability under this DPA is subject to the limitations set out in the Terms of Service.

14. Contact

Data Protection Officer: dpo@lightlink.uludeveloper.top