Data Processing Agreement (DPA)

This Agreement sets out how Clarvio processes personal data on behalf of its customers in accordance with UK data protection laws.

Clarvio Limited

Effective Date: 1st March 2026

This Data Processing Agreement (“Agreement”) forms part of the Terms of Service between Clarvio Limited (“Processor”) and the Customer (“Controller”).

1. Roles

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The Customer acts as the Data Controller.

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Clarvio Limited acts as the Data Processor.

The Controller determines the purposes and means of processing personal data.
The Processor processes personal data on behalf of the Controller.

2. Scope of Processing

The Processor will process personal data only:

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To provide the Services

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In accordance with the Controller’s instructions

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In compliance with applicable UK data protection laws

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Processing is limited to what is necessary to deliver the Services

Processing includes the storage, analysis, and modification of uploaded vehicle images and related data.

3. Types of Data

Personal data processed may include:

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Vehicle images

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Vehicle registration numbers

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Vehicle identification numbers (VIN)

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Associated metadata (e.g. timestamps, usage data)

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Images that may contain identifiable information

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User account data (if applicable)

4. Categories of Data Subjects

Data subjects may include individuals identifiable through vehicle-related data, such as vehicle owners or drivers.

5. Obligations of the Controller

The Controller warrants that:

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It has a lawful basis to process personal data

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It has the right to upload and share such data with the Processor

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It has provided any required notices to relevant individuals

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The Controller is responsible for ensuring compliance with all applicable data protection laws.

6. Obligations of the Processor

The Processor shall:

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Process personal data only on documented instructions from the Controller

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Ensure that persons authorised to process data are subject to confidentiality obligations

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Implement appropriate technical and organisational security measures

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Assist the Controller, where reasonably required, with responding to data subject requests

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Assist the Controller in meeting its obligations under UK GDPR

7. Sub-Processors

The Controller authorises the use of sub-processors (e.g. cloud hosting and infrastructure providers).

The Processor shall:

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Ensure sub-processors are bound by equivalent data protection obligations

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Remain responsible for the performance of sub-processors

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A list of current sub-processors is available upon request.

8. International Transfers

Where personal data is transferred outside the United Kingdom, the Processor shall ensure appropriate safeguards are in place, such as:

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UK Standard Contractual Clauses

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Transfers to countries with recognised adequacy decisions

9. Security

The Processor shall implement appropriate technical and organisational measures to protect personal data, including:

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Encryption in transit

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Access controls

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Monitoring and security safeguards

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Measures are regularly reviewed and updated to maintain security

10. Personal Data Breaches

The Processor shall notify the Controller without undue delay after becoming aware of a personal data breach affecting the processed data.

11. Data Retention and Deletion

Upon termination, personal data will be deleted or returned at the Controller’s request, unless retention is required by law.

12. Audit and Compliance

The Processor shall make available information reasonably necessary to demonstrate compliance with this Agreement.Audits shall be subject to reasonable notice, unless required by law.

13. Governing Law

This Agreement is governed by the laws of England and Wales.