Data processing addendum
This addendum sits alongside the terms. It is the Article 28 agreement between the firm and the provider.
The firm is the controller. SIMPS LTD (trading as Zap Trades) (17432160, The Lake Lodge, Foggathorpe, Selby, YO8 6PZ) is the processor for the personal data the firm puts into Zap Trades: staff, customers, callers, jobs, receipts, locations and assistant questions.
Processing is only to provide the product, keep it secure, and follow the firm’s instructions through the product. A sub-processor is used only for hosting, payments, telephony, email, DNS, address search, or the AI features the firm switches on. The current list is on the privacy policy: Hetzner, Google Gemini, OpenAI or Anthropic where the firm has saved its own key, xAI, Twilio, Stripe, Resend, Cloudflare, and OpenStreetMap Nominatim.
People who can see the data are limited to those who need it to run the service. Access by the platform operator is written to the audit log when it is done by impersonation. Secrets and payment card numbers are not stored in the clear.
If a personal-data breach is discovered, the processor tells the firm without undue delay, with what is known about what happened and who is affected. The firm decides whether to tell the ICO and the people concerned.
When the firm deletes the account, the personal data in that account is deleted from the live database. Backups age out on the host’s backup cycle. A copy can be exported before deletion.
The firm can audit this by asking hello@zaptrades.co.uk for the current sub-processor list and a description of the measures.
International transfers
Hetzner hosts the application in the European Union. xAI, Twilio, Stripe, Google and Resend process data in the United States. Those transfers use the UK International Data Transfer Agreement, or the UK Addendum to the EU standard clauses, and the UK-US data bridge where it applies to that provider. The same basis covers a firm’s own OpenAI or Anthropic key. Cloudflare provides DNS and email routing. Nominatim is used for address search.
This addendum lasts while the firm has an account. Questions go to hello@zaptrades.co.uk. ICO registration is pending.