Data Processing Agreement (DPA)

Last updated: January 2026

This Data Processing Agreement ("DPA") forms part of any agreement between Sparkvern LLC ("Processor") and the client ("Controller") where Sparkvern LLC processes personal data on behalf of the Controller.

1. Scope & Purpose

Sparkvern LLC processes personal data solely for the purpose of providing contracted services, in accordance with documented instructions from the Controller.

2. Roles & Responsibilities

  • Controller: Determines purposes and means of processing
  • Processor (Sparkvern LLC): Processes data on behalf of the Controller

3. Categories of Data & Data Subjects

Depending on the engagement, personal data may include employee data, customer or user data, and business contact data. Data subjects may include employees, customers, contractors, or end users.

4. Processor Obligations

Sparkvern LLC shall:

  • Process data only on documented instructions
  • Ensure confidentiality of personnel
  • Implement appropriate technical and organizational security measures
  • Assist the Controller with data subject rights requests
  • Notify the Controller of personal data breaches without undue delay
  • Delete or return personal data upon termination, unless legally required to retain it

5. Subprocessors

Sparkvern LLC may engage subprocessors for infrastructure or tooling. A current list can be provided upon request. All subprocessors are bound by equivalent data protection obligations.

6. International Data Transfers

Where data is transferred internationally, Sparkvern LLC ensures appropriate safeguards are in place in accordance with applicable law (e.g. Standard Contractual Clauses where applicable).

7. Audits

Upon reasonable notice, the Controller may audit Sparkvern LLC's compliance with this DPA, subject to confidentiality and security requirements.

8. Liability

Liability related to data protection is governed by the main service agreement.

9. Term & Termination

This DPA remains in effect for the duration of data processing under the applicable agreement.

10. Contact

Data protection inquiries: contact@sparkvern.com