Data processing agreement

Version 1.0, 4 November 2026

This agreement is between Shelter Suite Ltd (company 14975914, registered office c/o Linggard and Thomas Ltd, Kew An Lergh, Stret Myghtern Arthur, Nansledan, Newquay, Cornwall, TR8 4UX) ("Shelter Suite", "we") and the organisation that uses Shelter Suite (the "Customer", "you"). It forms part of your agreement to use Shelter Suite, including a free trial, and applies whenever we process personal data on your behalf. If anything in your main agreement conflicts with this one about personal data, this agreement wins.

1. Roles

1.1 For the personal data you and your users put into Shelter Suite ("Customer Data"), you are the controller and we are your processor, as those words are used in the UK GDPR and the Data Protection Act 2018 ("Data Protection Law").

1.2 You're responsible for having a lawful basis for the Customer Data, for the information you give people when you collect it (for example on your online forms), and for the instructions you give us. Schedule 1 describes the processing.

1.3 We're a controller, not your processor, for our own records about your organisation and its users (such as account, billing, support and sales records). Our privacy notice covers those.

2. What we will do

2.1 Instructions. We'll process Customer Data only on your documented instructions, which are this agreement, your use and settings of Shelter Suite, and anything else you ask in writing that we agree to. We'll tell you if we think an instruction breaks Data Protection Law. If the law requires us to process Customer Data in another way, we'll tell you first unless the law forbids it.

2.2 Confidentiality. Everyone we allow to access Customer Data is bound to keep it confidential, and only accesses it when needed to run, support or improve the service for you.

2.3 Security. We'll keep in place the technical and organisational measures in Schedule 2, and keep them appropriate to the risk as technology and threats change.

2.4 Sub-processors. You give us general permission to use the sub-processors listed in Schedule 3. We'll tell you at least 30 days before adding or replacing one, so you can object on reasonable data protection grounds; if we can't resolve your objection, you can end the affected service without penalty. We'll put a written contract in place with each sub-processor giving the same level of protection as this agreement, and we remain responsible to you for them.

2.5 Transfers outside the UK. We'll only transfer Customer Data outside the UK where Data Protection Law allows it, for example to a country with UK adequacy regulations or under the UK International Data Transfer Agreement or Addendum. Schedule 3 shows where each sub-processor handles data.

2.6 Helping with people's rights. Shelter Suite lets you find, export, correct and delete records, and record marketing opt-outs. If someone contacts us directly about Customer Data, we'll pass the request to you without undue delay and won't answer it ourselves unless you ask us to. We'll give you reasonable further help where the tools aren't enough.

2.7 Personal data breaches. If we become aware of a personal data breach affecting Customer Data, we'll tell you without undue delay, and in any event within 48 hours, so you can meet your own 72-hour deadline to tell the ICO. We'll give you the information we have (what happened, the data and people likely to be affected, likely consequences and what we're doing about it), add to it as we learn more, and help you contain and investigate it.

2.8 Other help. We'll give you reasonable help with data protection impact assessments and any consultation with the ICO about Shelter Suite.

2.9 Audits. We'll make available the information you reasonably need to show that we meet this agreement. You (or an independent auditor bound by confidentiality) may audit our compliance once a year on 30 days' notice, or at any time after a personal data breach or if the ICO asks. Audits are at your cost and must not put other customers' data at risk.

3. When the agreement ends

3.1 When you stop using Shelter Suite, you can ask us for an export of your Customer Data in a format you can use elsewhere, such as CSV files. Unless you tell us otherwise, we'll delete Customer Data within 90 days of the end of your agreement, including from backups as they expire, unless the law requires us to keep it.

3.2 Free trials. During a trial you agree to use made-up details. Trial data is deleted after the trial ends, as set out in the trial terms. Customers start on a fresh Shelter Suite.

4. General

4.1 Each party's liability under this agreement is subject to the limits in your main agreement with us, except where the law doesn't allow liability to be limited.

4.2 We may update this agreement to reflect changes in the law or in Shelter Suite. We'll tell you at least 30 days before any change that reduces your protection.

4.3 This agreement is governed by the law of England and Wales, and the courts of England and Wales have exclusive jurisdiction.

Schedule 1: The processing

Schedule 2: Security measures

• Hosted on UK servers, managed by Shelter Suite, and backed up throughout the day.
• Encryption of data in transit (HTTPS) and at rest.
• Individual user accounts; role-based access (trustee, lead coordinator, area co-ordinator) with optional permissions, and area co-ordinators limited to the areas and counties they cover.
• A history of every change to each record and who made it; deleted records can be restored by trustees.
• Read-only public website keys that can be revoked at any time; third-party keys (such as an email tool's) stored encrypted and never shown again.
• Access by Shelter Suite staff limited to running, supporting and improving the service, under confidentiality.
• Regular security reviews, and a personal data breach response plan.
• Professional indemnity insurance; Shelter Suite Ltd is registered with the ICO (ZB628453).

Schedule 3: Sub-processors

The main sub-processors are listed below. We'll send the full, current list on request, and tell you before it changes (section 2.4).

Services you choose to connect yourself, such as your email newsletter tool or a microchip registry, are your own providers, not our sub-processors.