Data Processing Agreement

1.Parties and roles

This Data Processing Agreement is between the client agency (the Controller) and Alunio, operated by Louis-François Geoffrion with Alunio Ltd in formation, which will assume this agreement in full on incorporation (the Processor). Under UK GDPR the agency decides why and how client personal data is used; Alunio processes it only as this agreement and the agency's documented instructions allow.

2.Subject matter, nature and purpose

Alunio processes residential transaction progression data for one purpose: detecting delay, scoring deal risk, and drafting chase correspondence for the agency's own staff to review and send. Processing lasts for the term of the service agreement.

• Data subjects: buyers and sellers in the agency's transactions; the professional parties around them (solicitors, brokers, lenders); agency staff.
• Data categories: deal stages and dates, property addresses, agreed prices, party names and business contact details, correspondence the agency forwards to a deal's intake address.
• Not processed: AML records, identity documents, client bank details, mortgage applications. The product is deliberately built without them.

3.Documented instructions

Alunio processes personal data only on the agency's documented instructions, which are: the service agreement, this DPA, and the agency's use of the product itself. Alunio does not use client personal data for its own purposes, does not sell it, and does not use it to train AI models. If an instruction would, in Alunio's view, breach UK data protection law, Alunio informs the agency before acting.

4.Confidentiality

Access to production data is limited to persons bound by confidentiality obligations. Today that is one person, the founder; there is no support team and no contractor access. Any future staff receive access only under written confidentiality terms and only to the extent support requires.

5.Security measures

Article 32 measures in force today:

• Encryption in transit (TLS) and at rest;
• Tenant isolation enforced by PostgreSQL row level security on every customer table, applied by the database on every query;
• Role separation: client sessions cannot write to evidence or audit tables;
• An immutable, database enforced change log recording who changed which field of a deal, from what value to what value, and when;
• Rate limiting and same origin checks on state changing endpoints;
• No production data on laptops, spreadsheets or personal drives.

6.Sub processors

The agency gives general authorisation for the sub processors below, and that is the complete list. Alunio gives at least 14 days notice before adding or replacing one, during which the agency may object on reasonable data protection grounds.

Transfers outside the UK rely on the UK IDTA or the UK Addendum to the EU Standard Contractual Clauses, as noted above.

7.Assistance with data subject rights

If a buyer, seller or other data subject exercises a UK GDPR right against the agency, Alunio assists: locating the person's data, exporting it, correcting it, or deleting it where the agency instructs and law allows. Requests arriving directly at Alunio are forwarded to the agency without undue delay; the agency stays in control of the response.

8.Personal data breach

Alunio notifies the agency without undue delay, and in any event within 48 hours of becoming aware of a personal data breach affecting the agency's data, with the information Article 33(3) requires as it becomes available, and cooperates fully with the agency's own notification duties.

9.Export, return and deletion

During the term the agency can request a full export of its data in a standard machine readable format at any time. On contract exit, and equally if Alunio ever ceases operating, the agency receives 30 days notice where possible, a complete export, and then verified deletion of its data from production and backups as backup cycles expire, save for what law requires Alunio to retain. Return or deletion is the agency's choice.

10.Audit and records

Alunio keeps records of its processing activities and makes available the information reasonably necessary to demonstrate compliance with Article 28: this agreement, the sub processor list, the security description on the Security page, and the per deal change log inside the product. The agency may audit once per year on 30 days written notice, at its own cost, in a manner that does not put other agencies' data at risk.

11.Honesty clause

Alunio is a young product and says so. It does not yet hold ISO 27001 or SOC 2, and this agreement has not yet been stamped by outside counsel; it is offered for your compliance partner's review before you sign anything. If any claim on this page stops being true, the page changes the same day. Ask at louisgeoffrion@alunio.ai and you will get a straight answer.