Data Processing Agreement

1. Parties and Roles

This Data Processing Agreement (DPA) forms part of the agreement between the HVAC contractor entity using ComfortOS (Customer, Controller) and Better Cards, LLC (Better Cards, Processor).

Better Cards processes personal data contained in Customer's tenant workspace solely on documented instructions from Customer, except where required by law.

2. Subject Matter and Duration

Processing relates to provision of the ComfortOS platform, including hosting, backup, support, integrations, and security monitoring. Processing continues for the subscription term and any post-termination export window described in the Terms of Service.

3. Categories of Data and Subjects

Personal data may include:

• Customer personnel: names, emails, phone numbers, roles, and authentication data.
• End customers: contact details, service addresses, equipment information, job history, payment status, and communications metadata.
• Call and message content where recordings or transcripts are enabled by Customer.

4. Processor Obligations

Better Cards will:

• Process data only on Customer instructions as configured in the product and support tickets.
• Ensure personnel with access are bound by confidentiality.
• Implement appropriate technical and organizational security measures.
• Assist Customer with data subject requests where technically feasible.
• Notify Customer without undue delay after becoming aware of a personal data breach affecting Customer data.
• Delete or return Customer data upon termination, subject to legal retention requirements.
• Make available information necessary to demonstrate compliance and allow audits upon reasonable notice.

5. Subprocessors

Customer authorizes Better Cards to engage subprocessors listed in our Subprocessor page. Better Cards will impose data protection obligations on subprocessors substantially similar to this DPA and remain responsible for their performance.

6. International Transfers

Where personal data is transferred outside the EEA, UK, or Switzerland, Better Cards will implement appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms.

7. Contact

DPA inquiries: [email protected]

Better Cards, LLC · getcomfortos.com