LEGAL
Data Processing Agreement
Last updated: October 25, 2026 · Effective: October 7, 2026
1. Purpose
This Data Processing Agreement ("DPA") governs the processing of personal data by Caelum Mountain LLC ("Processor") on behalf of the client ("Controller") in connection with the Services provided under the Terms of Service. This DPA is incorporated into and forms part of the Terms of Service.
2. Scope of Processing
The Processor processes personal data only as necessary to provide the Services, including: (a) custom software development; (b) IT consulting and audits; (c) systems architecture and modernization; (d) managed IT services. The Processor does not process personal data for any other purpose.
3. Data Subject Categories
Personal data may relate to: (a) the Controller's employees and contractors; (b) the Controller's customers and end users; (c) the Controller's business partners. The specific categories depend on the Services engaged.
4. Data Types
Personal data processed may include: names, email addresses, phone numbers, job titles, IP addresses, device information, and any other data provided by the Controller in connection with the Services.
5. Processor Obligations
- Process personal data only on documented instructions from the Controller.
- Ensure that persons authorized to process personal data are bound by confidentiality.
- Implement appropriate technical and organizational security measures.
- Assist the Controller in responding to data subject requests.
- Notify the Controller without undue delay of any personal data breach.
- Delete or return all personal data upon termination of the Services.
6. Sub-processors
The Processor may engage sub-processors (e.g., cloud hosting providers, payment processors) to assist in providing the Services. The Processor will notify the Controller of any new sub-processors and provide the Controller with an opportunity to object.
7. International Transfers
Personal data may be transferred to and processed in the United States. The Processor ensures appropriate safeguards are in place for any international transfers, including Standard Contractual Clauses where required.
8. Data Retention
Personal data is retained only for as long as necessary to provide the Services and comply with legal obligations. Upon termination, data is deleted or returned within 30 days.
9. Audit Rights
The Controller may audit the Processor's compliance with this DPA upon reasonable notice. The Processor will cooperate with such audits.
10. Contact
Caelum Mountain LLC
1209 MOUNTAIN ROAD PL NE, STE R
ALBUQUERQUE, NM 87110, United States
info@caelummountain.online