Parties and acceptance
This addendum forms part of the Redomon service agreement between the customer identified by the workspace and accepted order, and Manuel García Nicastro, an individual operator, CUIT 20-50046009-2, La Plata, Buenos Aires, Argentina, operating as Redomon. Each party’s privacy contact is its designated account contact; Redomon’s contact is hello@redomon.com. It becomes binding on affirmative acceptance of the service agreement by an authorized representative, or separate signature. A dated acceptance record must identify the customer and version. Publication alone does not execute an agreement.
Roles and applicable law
The customer determines the purposes and essential means of processing its CRM and Product Analytics personal data and is the controller. Redomon is the processor, or subprocessor where the customer is itself a processor acting with its controller’s authorization. In the latter case the customer must pass through lawful instructions and necessary upstream obligations. Processing of Redomon’s own account administration data and Polar’s independent purchase processing is described in the privacy notice and is outside the processor instructions in this addendum.
This DPA supports Redomon’s global B2B service. Applicable data protection law means laws governing the relevant processing, including EU GDPR, UK GDPR and the UK Data Protection Act 2018, CCPA/CPRA and other applicable US state privacy laws, and other mandatory international or national privacy rules. Argentina’s Ley 25.326 and implementing rules apply to the extent they govern the operator or processing; the operator’s location does not make Argentina the customer market. References to GDPR obligations also cover corresponding UK GDPR obligations where applicable. Terms such as personal data, controller, processor, processing and personal data breach have their meanings under applicable law. A customer instruction cannot authorize processing prohibited by law.
Processing description
Processing is limited to supplying the customer-configured Redomon CRM and Redomon Product Analytics, administering customer-authorized access, providing requested support, securing the service, returning data and deleting it. CRM includes contacts for people and organizations, mail synchronization and sending through IMAP and SMTP, AI summaries and drafts, documents and files. Product Analytics includes events, funnels, retention, page and product usage and CRM-contact integration. Neither plan access nor an administrator role authorizes an unrelated processing purpose.
The subject matter is management of business relationships and related communications and product usage in a customer workspace. Processing may involve collection, recording, structuring, storage, retrieval, display, authorized editing, synchronization, transmission, export, restriction and deletion. Analytics processing includes event ingestion, grouping, aggregation, funnel and retention computation and customer-instructed contact linking. AI inference is limited to customer-requested summaries or drafts. Processing lasts during service and the limited return and deletion period, or as required by law.
Data subjects and categories
Data subjects include website visitors and application users as well as customer users and staff, prospects, clients, suppliers, corporate contacts, mailbox correspondents and people referred to in authorized records or messages. Data may include names, business contact details, organization and role, relationship history, deal and pipeline information, notes, cases, email subjects and bodies, sender and recipient headers, attachments, access identifiers and related metadata, event names, timestamps, event properties, page and product usage, pseudonymous or identified user references, document contents and file metadata. Content is determined by the customer. Special-category data, criminal-offence records and regulated sensitive datasets are outside the intended scope unless the parties expressly agree in writing to appropriate safeguards. The customer must avoid connecting mailboxes or uploading files likely to introduce such data without that agreement.
Customer responsibilities
The customer is responsible for lawful collection and instructions, accuracy where within its control, required notices, lawful bases and any necessary consents or special-category conditions. It must have authority over connected mailboxes and observe correspondence confidentiality, workplace and third-party privacy requirements. Neither a mailbox password nor an administrator role proves a lawful basis. The customer must ensure that its users understand the sharing effects of workspace permissions and outbound messages.
Documented instructions
The service agreement, accepted configuration, authorized user actions and written support requests are documented instructions. Redomon will process personal data only on those instructions, including for international transfers, unless applicable law requires otherwise. We will inform the customer before legally required processing unless prohibited by law. Where GDPR Article 28 applies, any exception to customer instructions for legally required processing or continued storage is limited to the Union or Member State law exception that provision permits. A conflicting third-country demand must be assessed under applicable law and transfer safeguards; it is not treated as unrestricted permission to depart from instructions. We will promptly notify the customer where lawful and seek a compliant resolution before affected processing continues. We will immediately inform the customer if, in our opinion, an instruction infringes applicable data protection law and may pause the affected processing pending clarification. We will not sell customer personal data, use it for advertising, train general-purpose AI on it, or combine it for unrelated customer profiling.
Confidentiality and security
Persons authorized to access customer data must be bound by confidentiality or an equivalent statutory obligation, trained as appropriate to their role, and given access only as needed. Redomon will implement technical and organizational measures appropriate to the risk under Article 32 GDPR where applicable and Argentine security obligations, taking account of state of the art, costs, nature, scope, context and purposes of processing and risks to individuals. The safeguards below are contractual minimum requirements proportionate to the processing risk, not a certification.
Required safeguards include encrypted transport for public and provider connections; provider-supported encryption at rest for databases, objects and backups; protected credentials with restricted access and rotation after compromise; authenticated sessions; server-side workspace isolation and permission checks; least-privilege operational access; secure deployment and dependency maintenance; proportionate security logging without unnecessary message bodies or secrets; tested recovery arrangements with a documented backup lifecycle; verified export and deletion procedures; and incident detection, containment and escalation. Mailbox credentials or tokens must be encrypted and kept separate from ordinary application output and logs. AI prompts must be minimized. Redomon will not materially reduce agreed safeguards during the service. An exact encryption algorithm, certification, penetration-test program or recovery objective is not promised unless separately documented.
Subprocessors and objections
The customer generally authorizes the customer-data subprocessors identified on the accepted subprocessors page. Redomon will engage them only under written obligations providing substantially the same applicable data protection protections, including sufficient security guarantees, and remains responsible to the customer for their performance of those obligations. Independent controllers, including Polar for its own sale and tax processing, are not treated as customer-content subprocessors for those activities.
We will send the workspace’s designated contact at least 30 days’ advance notice before adding or replacing a customer-data subprocessor, including its identity, function and processing countries. The customer may object during that period on reasonable data protection grounds. We will discuss alternatives in good faith. If no reasonable solution is available before the affected processing begins, either party may terminate the affected service without penalty; we will arrange a proportional refund of unused prepaid fees for it. We will not route the objecting customer’s data to the new provider while the objection is unresolved. Security emergencies do not authorize skipping legally required authorization.
AI processing
AI inference is limited to the customer’s requested summaries or drafts and minimized selected context. AI inference uses zero data retention: the provider does not retain inputs or outputs or use them for training. This condition does not erase source CRM data or outputs saved in the workspace. Before any provider receives customer content, Redomon identifies its legal entity, processing countries and applicable transfer safeguards to the customer, binds it to appropriate written obligations, verifies the relevant configuration, and follows the subprocessor-notice and objection procedure. This provision does not itself name or approve an AI provider.
Locations and international transfers
Primary database storage and application Workers are hosted in Frankfurt, Germany. This is a service-region commitment, not a guarantee that all processing occurs in the EU. Cloudflare edge delivery, provider operations and support, customer-selected mailbox services, separately disclosed AI processing and necessary operator access from Argentina may involve other countries. Object storage, backup and onward-processing locations are governed by the disclosed provider configuration and applicable transfer safeguards; no EU-only processing or Frankfurt object-storage guarantee is made.
Transfers must comply independently with applicable Argentine rules and GDPR Chapter V where applicable. An applicable EU adequacy decision, including Argentina’s while valid and within its scope, may support a covered transfer. Where adequacy does not apply, the parties must put an appropriate transfer mechanism in place before the transfer, including the European Commission’s standard contractual clauses in Decision (EU) 2021/914 where applicable. Module Two ordinarily applies for a controller-to-processor transfer and Module Three for a processor-to-processor transfer. Selection must reflect the parties’ actual roles and the clauses’ legal scope.
Merely mentioning SCCs does not execute them. Where needed, the parties must execute or validly incorporate the unmodified applicable clauses and complete all elections and Annexes I, II and, where required, III, identifying parties, contacts, categories, purposes, countries, competent authority, safeguards and authorized subprocessors. An appropriate EU member-state law and courts must be selected under those clauses, rather than substituting the general La Plata venue. The parties must assess relevant destination laws and implement supplementary measures when required. For UK restricted transfers not covered by adequacy, the parties must validly adopt the UK International Data Transfer Agreement or the UK Addendum to the EU SCCs, completing its tables and required assessment; EU SCCs alone are insufficient. Swiss transfers require the applicable Swiss adaptations or approved mechanism where relevant. Argentine outbound transfers may require AAIP-approved model clauses or another valid safeguard; EU SCCs alone are not assumed to satisfy Argentine law. No transfer needing an incomplete mechanism may begin.
Breach notification
Redomon will notify the customer without undue delay after becoming aware of a personal data breach affecting its data. Incomplete investigation will not delay the initial notice. We will provide information then available concerning the nature of the breach, affected data and subjects, likely consequences, containment and remediation, and a contact point, supplementing it as facts develop. We will preserve relevant evidence and cooperate with reasonable mitigation. This duty is not conditional on admitting fault. The customer determines its own authority and individual notifications; Redomon will assist and will make its own legally required notifications. A processor’s notice is not deferred until the controller’s potential 72-hour reporting deadline.
Rights and regulatory assistance
Taking account of the processing and available information, Redomon will assist the customer with access, correction, deletion, portability, restriction, objections and other applicable rights. We will forward requests concerning customer data promptly and will not answer on its behalf except on instructions or where law requires. Assistance must allow the customer to meet applicable deadlines, including Argentine ten-calendar-day access and five-business-day correction or deletion requirements where applicable. We will also reasonably assist with security obligations, breach response, impact assessments and prior consultation with regulators.
Audits
Redomon will make available information reasonably necessary to demonstrate compliance with this addendum and Article 28 GDPR where applicable, and allow and contribute to audits, including inspections, by the customer or an independent auditor bound by confidentiality. Ordinary audits may be coordinated on reasonable notice and normally once annually, first using available documentation where sufficient. These administrative arrangements do not limit audits required by a credible incident, demonstrated noncompliance, regulator direction or law. Audits must avoid other customers’ data and unnecessary security disruption; genuinely sensitive details may be supplied through appropriate secure arrangements, not withheld so that verification becomes impossible. Routine assistance is included; extraordinary customer-specific work may carry a reasonable agreed charge, but not for remedying Redomon’s breach or as a condition of mandatory cooperation.
Return, export and deletion
At the customer’s choice, Redomon will return customer personal data in a reasonably usable machine-readable format or delete it after service ends, and delete existing copies unless applicable law requires storage. A verified administrator may request this at hello@redomon.com without relying on a future self-service export button. Unless earlier deletion is requested, the customer instructs Redomon to retain data solely for return during a 30-day post-termination export period; it is not permission for other reuse.
Unless you request earlier deletion, the post-termination export window lasts 30 days and permits retention solely to return your data. We delete customer content from active systems within 30 days after that window ends. A validated deletion instruction is carried out without undue delay and within the shortest applicable legal deadline; the routine cleanup period does not extend those deadlines. Restricted backup copies expire within a further 90 days after active-system deletion, only where that limited retention is lawful. They remain isolated from ordinary use, and deletion instructions are reapplied after restoration. Legally required retention is limited to relevant records, restricted to its lawful purpose, and ends when its justification ends.
Disconnecting a mailbox stops future sync; deleting imported data does not erase originals or messages delivered to recipients. On closure we will revoke stored mailbox access credentials or tokens and delete our copies consistent with the instructions and applicable deadlines. The customer must separately manage copies it exports and records held by its own providers.
Government requests
If a government request concerns customer data, we will assess its validity, limit any disclosure to what is legally required, challenge an unlawful or disproportionate request where reasonably justified, and notify the customer unless prohibited. We will not voluntarily give authorities unrestricted access.
Priority, liability and changes
This addendum prevails over conflicting general terms for personal-data processing. Applicable transfer clauses prevail over it. Contractual liability limits do not diminish data subjects’ statutory rights, regulator powers or liabilities that cannot legally be limited. The service terms describe a separate enhanced contractual cap for ordinary negligent confidentiality and data protection breaches, subject to their unlimited carve-outs. No contractual cap restricts non-waivable statutory liability, data-subject rights, regulator powers or applicable transfer-clause remedies. Disputes follow the service agreement only insofar as compatible with mandatory data protection jurisdiction and transfer clauses. Processing and confidentiality duties survive until data is returned or deleted and any required retention ends.
Material changes to this addendum require advance direct notice and a lawful contractual basis; publication alone is not an instruction for a new purpose, a transfer mechanism or authorization to reduce protections.
Additional retention and transfer safeguards
Routine post-termination cleanup does not establish an additional retention entitlement. It does not extend the deadline for a valid data-subject rights request or a controller deletion instruction. Such instructions must be carried out without undue delay and within the shortest applicable legal deadline. Any residual backup copy must remain isolated from ordinary use, must not be restored without reapplying deletion, and may be retained only where that treatment is lawful. A technical backup schedule is not a blanket exception to erasure rights.
For Argentine outbound-transfer analysis, recognized adequate EU/EEA destinations may support covered transfers without separate model clauses while the relevant recognition applies. Onward processing, provider support and non-adequate destinations must be assessed separately. Crossing the Argentina/EU border alone does not establish that SCCs are required.
California and US state processor terms
Where customer personal information is governed by CCPA/CPRA, the customer discloses it to Redomon only for these limited business purposes, as configured and instructed: hosting and organizing business contact, organization, deal, note, case, document and file records; ingesting customer-instructed events, calculating funnels and retention, reporting page and product usage and linking events to CRM contacts; synchronizing authorized mailbox content; transmitting user-authorized messages; generating requested summaries or drafts; controlling workspace access; securing and supporting those operations; and returning or deleting the records. Product access does not authorize additional processing purposes.
For that information, Redomon acts as a service provider or contractor as legally applicable, not as a third party free to repurpose it. Redomon will not sell or share it as those terms are defined by CCPA/CPRA; retain, use or disclose it for a purpose other than those specified above or otherwise expressly permitted by applicable law; retain, use or disclose it outside the direct business relationship except as expressly permitted by law; or combine it with information from other customers, other sources or Redomon’s own interaction with an individual except as expressly permitted by CCPA/CPRA. Redomon certifies that it understands these restrictions and will comply with them.
Redomon will comply with applicable CCPA/CPRA requirements and provide the same level of privacy protection required of businesses for the information concerned, including reasonable security appropriate to its nature. Redomon will promptly notify the customer if it determines it can no longer meet those obligations. On notice, the customer may take reasonable and appropriate steps to verify compliant use and stop and remediate unauthorized use, including the audits and inspections allowed by this DPA and reasonable requests for evidence of deletion.
Redomon will enable and assist the customer to comply with applicable consumer requests. The customer will promptly communicate the request and necessary instructions; Redomon will notify the customer of requests it receives and cooperate without unauthorized disclosure. Subcontractors processing this information must be bound by written contracts meeting the applicable CCPA/CPRA requirements, including these purpose restrictions and protection duties. Redomon will cooperate with legally required customer cybersecurity audits, risk assessments and applicable automated-decisionmaking obligations by supplying relevant information within its possession, custody or control, without misrepresentation. This does not authorize a prohibited AI use.
Where another US state privacy law applies, Redomon will process only the customer's lawful instructions for the stated purpose, nature and duration, bind authorized personnel to confidentiality, apply the security and subcontractor protections above, assist with applicable rights and assessments, provide required compliance information and assessments, and return or delete information as instructed unless legally required to retain it. Mandatory statutory requirements control over conflicting contractual limits.