Data processing agreement

Parties

The controller is the shop that holds a Junto account. The processor is the company the shop contracts with: Servio LLC (ID 405892057, Tbilisi, Georgia) for a shop in Georgia, KaiQR LLC (Dover, Delaware, USA) for a shop elsewhere. KaiQR LLC engages Servio LLC, Junto’s operator, to carry out the processing; the shop authorises that.

Where the shop is in the EU and we are outside it, this agreement includes the European Commission’s standard contractual clauses (module two, controller to processor) by reference; where there is a conflict, the clauses prevail.

Subject matter

Running Junto for the shop: storing and showing its customers, cars, bookings, work orders, photos, invoices, payments and reviews; sending the texts and notifications the shop triggers; producing its documents, exports and reports.

Duration

As long as the shop has a Junto account, then the retention described in the privacy policy: 90 days of read-only access after a missed payment, and deletion 12 months after cancellation or sooner on the shop’s written request.

Nature and purpose

Storage, display, search, change, sending of messages, backups and deletion of the data, only to provide Junto to the shop and its customers. We do not use the shop’s customer data for our own purposes, except the anonymised vehicle history by VIN the shop agreed to in the terms.

Data subjects and categories

• Data subjects: the shop’s customers (private people and the staff of its corporate clients), the shop’s staff, and family members a car owner shares a car with.
• Categories: names, phone numbers, email addresses, vehicles (plate, VIN, make, model, mileage), bookings and visits, work done and prices, photos of vehicles and damage, signatures at check-in, invoices and payments, reviews, staff hours and pay.
• No special categories of data are needed to use Junto; a shop must not store any in free-text fields or photos.

Instructions

We process the data only on the shop’s documented instructions: these terms, the settings the shop chooses in Junto and what its staff do in the program. We tell the shop if an instruction seems to us to break the law.

Our own staff access the shop’s data only to run the service, to answer the shop’s support request, or when the law requires it; such access is logged.

Confidentiality

Everyone we allow to process the data is bound by confidentiality, by contract or by law, and is trained for it.

Security (GDPR Art. 32)

• Every connection is encrypted (TLS); passwords are stored only as hashes; the apps keep their sessions in the phone’s secure storage.
• Each shop’s data is separated by shop in the database and in file storage, and shown only to people with a role at that shop; photos are served through an access check.
• Encrypted daily backups to a separate location, kept for 30 days; restores are tested.
• Administrative access and admin actions are logged; sign-in attempts are rate-limited.
• We review these measures when the service changes and at least once a year.

Sub-processors

The shop authorises the following sub-processors. We tell shops of a planned change by email or in the program at least 30 days before it takes effect, and a shop that objects on reasonable grounds may end its subscription before the change.

• Hetzner Online GmbH (Germany): servers, database and backups.
• An SMS gateway in Georgia: texts to Georgian numbers (the shop’s customers’ numbers and the text).
• Resend, Inc. (USA): emails sent by Junto (addresses and the email’s content).
• Stripe, Inc. (USA): the subscription of a shop outside Georgia (the shop’s and its owner’s details, never its customers’ data).
• Apple Inc. and Google LLC (USA), through Expo: delivery of notifications to the apps (device tokens and the notification’s text).

Requests from data subjects

A request a customer sends us about the shop’s records is forwarded to the shop within 5 working days; we help the shop answer it with the program’s tools (search, export, correction, deletion). Requests about Junto accounts we answer ourselves.

Personal data breaches

We tell the shop of a personal data breach affecting its data without undue delay and no later than 48 hours after we become aware of it, with what we know, what we are doing and whom to contact, and we keep the shop informed.

Return and deletion

The shop can download all of its data at any time from the subscription page, in read-only mode too. After the subscription is cancelled the data is kept for download and deleted 12 months later, or sooner on the shop owner’s written request, except what tax law requires us to keep.

What a deletion leaves is listed in the privacy policy: staff accounts that also work elsewhere, car owners’ own accounts, our administration log with the shop removed, and our invoices to the shop.

Audits

On request we give the shop the information it needs to show that this agreement is kept, and once a year, or after a breach, we allow an audit by the shop or an auditor bound by confidentiality, at a time agreed in advance and at the shop’s cost.

Transfers

The data is stored in Germany. Servio LLC accesses it from Georgia to run the service; for a shop in the EU that access is covered by the standard contractual clauses included in this agreement and by the measures above. Our US sub-processors are engaged under the EU–US Data Privacy Framework or standard contractual clauses.

The shop’s own duties

• The shop has a lawful basis for the data it keeps in Junto and for the texts it sends, and respects a customer’s refusal.
• The shop tells its customers that their records are kept in Junto and how to exercise their rights, and answers their requests as the controller.
• The shop meets the rules of its own country, for example the GDPR in Spain, the Ley Federal de Protección de Datos Personales en Posesión de los Particulares in Mexico, Law 1581 of 2012 in Colombia, and the Law on Personal Data Protection in Georgia.

Who runs Junto

Junto (junto.ge and its apps) is owned and operated by Servio LLC, Tbilisi, which is also the seller for shops in Georgia. For shops outside Georgia the seller and contracting party is KaiQR LLC, Delaware, which licenses Junto from Servio LLC; payments abroad are taken by Stripe as the merchant of record.