Data Processing Agreement

1. Purpose and Scope

This Data Processing Agreement ("DPA") forms part of the service agreement between SAITECH Solutions LLC ("Processor") and the Client ("Controller") and governs the processing of personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA).

2. Definitions

For the purposes of this DPA:

• "Personal Data" means any information relating to an identified or identifiable natural person
• "Processing" means any operation performed on personal data
• "Controller" means the entity that determines the purposes and means of processing
• "Processor" means the entity that processes personal data on behalf of the Controller
• "Data Subject" means the individual whose personal data is being processed
• "Supervisory Authority" means the relevant data protection authority

3. Processing Details

3.1 Subject Matter and Duration

The subject matter and duration of processing are defined in the service agreement. Processing will continue for the duration of the service relationship and as required for legal compliance thereafter.

3.2 Nature and Purpose of Processing

SAITECH Solutions LLC, founded by experienced engineers from diverse international backgrounds, processes personal data for the following purposes:

• Delivery of AI and IoT consulting services
• Implementation of custom software solutions
• System integration and technical support
• Training and knowledge transfer
• Project management and communication

3.3 Categories of Personal Data

The types of personal data that may be processed include:

3.4 Categories of Data Subjects

Data subjects may include:

• Client employees and contractors
• End users of implemented systems
• Business contacts and stakeholders
• Third-party users of integrated systems

4. Processor Obligations

4.1 Processing Instructions

SAITECH Solutions LLC will:

• Process personal data only on documented instructions from the Controller
• Inform the Controller if instructions violate applicable data protection laws
• Not process personal data for purposes other than those instructed
• Implement appropriate technical and organizational measures

4.2 Confidentiality

We ensure that personnel authorized to process personal data:

• Are bound by confidentiality obligations
• Receive appropriate data protection training
• Have access only to data necessary for their role
• Follow established security procedures

5. Security Measures

5.1 Technical Safeguards

• Encryption: Data encrypted in transit and at rest using industry-standard algorithms
• Access Controls: Multi-factor authentication and role-based access
• Network Security: Firewalls, intrusion detection, and secure VPNs
• Backup Systems: Regular backups with encryption and access controls
• Monitoring: Continuous security monitoring and logging

5.2 Organizational Measures

• Security Policies: Comprehensive information security framework
• Staff Training: Regular security awareness and data protection training
• Incident Response: Established procedures for security incidents
• Vendor Management: Due diligence and contracts with third-party providers
• Compliance Audits: Regular security assessments and compliance reviews

5.3 Certifications and Standards

Our security program aligns with recognized standards:

• ISO 27001 Information Security Management
• SOC 2 Type II Security Controls
• NIST Cybersecurity Framework
• Industry-specific security requirements

6. Sub-processors

6.1 Authorization

The Controller authorizes SAITECH Solutions LLC to engage sub-processors, subject to the conditions set out in this DPA. Current sub-processors are listed below.

6.2 Current Sub-processors

6.3 Sub-processor Changes

We will provide 30 days' notice of any additions or changes to sub-processors. The Controller may object to changes for legitimate data protection reasons.

7. Data Subject Rights

SAITECH Solutions LLC will assist the Controller in fulfilling data subject rights requests, including:

8. Personal Data Breach

8.1 Breach Notification

In case of a personal data breach, SAITECH Solutions LLC will:

• Notify the Controller without undue delay (within 72 hours when possible)
• Provide all available information about the breach
• Assist with breach assessment and regulatory notifications
• Implement remediation measures to address the breach
• Document the incident and response actions taken

8.2 Breach Information

Breach notifications will include, where possible:

• Description of the nature and scope of the breach
• Categories and approximate number of data subjects affected
• Categories and approximate number of personal data records
• Likely consequences of the breach
• Measures taken or proposed to address the breach

9. Data Protection Impact Assessment

SAITECH Solutions LLC will assist the Controller with Data Protection Impact Assessments (DPIAs) when required, providing:

• Technical documentation of processing activities
• Security measures and safeguards implemented
• Risk assessment and mitigation strategies
• Expert consultation on data protection matters

10. International Data Transfers

10.1 Transfer Mechanisms

As a US-based company (Wyoming) with international team members, when personal data is transferred outside the EEA, we ensure appropriate safeguards through:

• Adequacy Decisions: Transfers to countries with adequate data protection
• Standard Contractual Clauses: EU Commission approved SCCs
• Binding Corporate Rules: For intra-group transfers
• Certification Schemes: Recognized data protection certifications

10.2 Additional Safeguards

We implement additional technical and organizational measures:

• Enhanced encryption for data in transit and at rest
• Pseudonymization and anonymization where possible
• Access controls and monitoring for international transfers
• Regular review of transfer impact assessments

11. Audits and Compliance

11.1 Audit Rights

The Controller may conduct audits or inspections, or appoint a qualified third party, to verify compliance with this DPA, subject to:

• Reasonable advance notice (minimum 30 days)
• Confidentiality obligations for audit personnel
• Limitation to reasonable frequency (typically annual)
• Controller's responsibility for audit costs

11.2 Compliance Documentation

We maintain and provide access to:

• Records of processing activities
• Security policies and procedures
• Training records and certifications
• Third-party security assessments
• Incident logs and breach records

12. Data Return and Deletion

Upon termination of services, SAITECH Solutions LLC will, at the Controller's choice:

• Return Data: Provide personal data in a structured format
• Secure Deletion: Permanently delete all copies of personal data
• Retention Exception: Retain data only as required by applicable law
• Certification: Provide written confirmation of data deletion

13. Liability and Indemnification

Each party's liability for data protection violations is governed by applicable law and the main service agreement. Both parties agree to:

• Cooperate in defending against third-party claims
• Share liability costs in proportion to responsibility
• Provide mutual assistance in regulatory proceedings
• Maintain appropriate insurance coverage

14. Contact Information

For data protection matters and DPA-related inquiries, please contact: