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Data Processing Agreement

Last updated: July 2026

For customers subject to GDPR and similar laws — how we process personal data on your behalf, as your processor.

1.Roles

For personal data you bring into GenieCentral (such as your customers' contact details), you are the data controller and GenieCentral — operated by AIVIGIL MSP (trading as Genie Central), 1309 Coffeen Avenue STE 1200, Sheridan, WY 82801, USA — is the data processor. We process that data only to provide the service and on your documented instructions.

2.Scope of processing

Subject matter: providing GenieCentral, an AI employee and CRM that answers calls and texts, books jobs, and keeps your customer operations in one place.

Duration: for the term of your subscription plus any limited retention period.

Data subjects: your customers, leads, and contacts. Data types: identifiers, contact details, call and text records, and the content you choose to store.

3.Our obligations

Process personal data only on your instructions and for the agreed purposes.

Ensure people who process the data are bound by confidentiality.

Apply appropriate technical and organizational security measures (encryption in transit and at rest, access controls, monitoring).

Assist you with data-subject requests, breach notifications, and impact assessments.

4.Sub-processors

We use vetted sub-processors (for hosting, payments, email delivery, and AI model providers) under written terms that require equivalent protection. We'll maintain a current list and give you notice of changes so you can object.

5.International transfers

Where personal data is transferred across borders, we rely on appropriate safeguards such as Standard Contractual Clauses or an adequacy decision.

6.AI model providers

Prompts and content processed by third-party AI providers are handled under business/enterprise terms that prohibit using your data to train their models. Outward-facing actions require your approval.

7.Security incidents

If we become aware of a personal-data breach affecting your data, we'll notify you without undue delay and share the information you need to meet your own obligations.

8.Deletion & return

On termination, we'll delete or return your personal data at your choice, except where retention is required by law.

9.Audits

We'll make available the information needed to demonstrate compliance and, on reasonable request and notice, support audits consistent with protecting other customers' confidentiality.

10.Governing law & contact

This agreement is governed by the laws of the State of Wyoming, USA. For DPA requests, email [email protected].

Questions about this policy? Email [email protected] and a human will help.