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Data Processing Agreement

Last updated: November 6, 2026

1. Parties and Scope

This Data Processing Agreement ("DPA") is between the customer that accepts the DoBeacon Terms of Service ("Customer") and FJM Consulting LLC, a Wyoming limited liability company at 30 N Gould St, Ste R, Sheridan, WY 82801 that operates DoBeacon ("DoBeacon"). It forms part of the Terms and applies whenever DoBeacon processes personal data contained in Customer Data on the Customer's behalf ("Customer Personal Data"). It covers the EU and UK General Data Protection Regulation and US state privacy laws such as the California Consumer Privacy Act (together, "Data Protection Laws"). If this DPA and the Terms conflict, this DPA wins on data protection matters.

Customers who need a signed copy can ask for a countersigned PDF of this DPA at hello@dobeacon.com.

2. Roles and Instructions

The Customer is the controller and DoBeacon is the processor (a "service provider" under US state laws). DoBeacon processes Customer Personal Data only on the Customer's documented instructions, which are the Terms, this DPA and the Customer's use and configuration of the Service. DoBeacon will tell the Customer if it believes an instruction breaks Data Protection Laws. DoBeacon will not sell or share Customer Personal Data, use it for any purpose other than providing the Service, or combine it with data from other customers.

3. Confidentiality

Everyone at DoBeacon who can access Customer Personal Data is bound by a duty of confidentiality and has access only where needed to run or support the Service.

4. Security

DoBeacon maintains the technical and organizational measures in Annex 2 and may improve them over time, as long as overall protection is not reduced.

5. Sub-processors

The Customer authorizes DoBeacon to use the sub-processors listed on our sub-processor page. DoBeacon will update that page at least 30 days before a new sub-processor starts processing Customer Personal Data. The Customer may object on reasonable data protection grounds within that period; if we cannot resolve the objection, the Customer may close its account and receive a refund of any prepaid fees for the period after closure. DoBeacon binds each sub-processor to data protection terms at least as protective as this DPA and remains responsible for their performance.

6. Assistance

Taking into account the nature of the processing, DoBeacon will help the Customer respond to requests from individuals exercising their rights, and with data protection impact assessments and consultations with authorities. If DoBeacon receives a request directly from one of the Customer's visitors or learners, it will pass the request to the Customer and not respond itself unless the Customer asks it to.

7. Personal Data Breaches

DoBeacon will notify the Customer without undue delay, and in any case within 72 hours, after becoming aware of a personal data breach affecting Customer Personal Data. The notice will describe the breach, the data and individuals likely affected, its likely consequences and the steps taken, with further details as they become available.

8. Deletion or Return

DoBeacon deletes Customer Personal Data on the schedule in Annex 3. When the Customer closes its account, it can export reports from the Service and, during the 30-day restore period, ask DoBeacon for a copy of its Customer Data in a commonly used format. After that, DoBeacon erases the Customer Personal Data, except where the law requires it to keep some of it. The Customer may also instruct DoBeacon to delete specific Customer Personal Data earlier by contacting us.

9. Audits

DoBeacon will make available the information reasonably needed to demonstrate compliance with this DPA, including answers to security questionnaires. Where that is not enough, the Customer may audit DoBeacon's compliance once a year, on at least 30 days' notice, at its own cost and subject to confidentiality.

10. International Transfers

DoBeacon processes Customer Personal Data in the United States. For transfers from the European Economic Area, the Standard Contractual Clauses adopted by the European Commission in Decision 2021/914 are incorporated into this DPA: Module 2 (controller to processor) applies, with the Customer as data exporter and DoBeacon as data importer, the optional docking clause and Clause 9(a) Option 2 (general authorization with the notice period in section 5), and Ireland as the governing law and forum. For the United Kingdom, the UK International Data Transfer Addendum applies, and for Switzerland the clauses apply with references adapted to Swiss law. Annexes 1 and 2 complete the clauses' appendix.

Annex 1 — Details of Processing

  • Subject matter and purpose: providing the DoBeacon Service: in-product tours, an AI assistant, feedback and quizzes, analytics and staff training.
  • Duration: while the Customer's account is active, then until deletion under Annex 3.
  • Individuals: the Customer's website visitors and end users, its learners and staff, and its workspace members.
  • Personal data: visitor IDs; user IDs and email addresses the Customer passes to DoBeacon; tour activity; quiz and feedback answers including free text; assistant conversations; support request emails; learner names, emails, course results, certificates and completion IP addresses.
  • Special categories: none intended. The Customer must not use the Service to collect them.

Annex 2 — Security Measures

  • Encryption of all traffic in transit (TLS) and of the database at rest.
  • Passwords stored only as salted hashes (bcrypt).
  • Every request checks that the signed-in user belongs to the account or workspace whose data it reads or changes, keeping each customer's data separate.
  • Production access limited to the people who run the Service.
  • Daily encrypted database snapshots, each kept for 8 days, and a separate daily encrypted copy of the database kept for 30 days in Google Cloud Storage, so data can be restored after a failure.
  • Automated deletion on the retention schedule in Annex 3.
  • Hosting and database infrastructure run by the providers on the sub-processor page, under their own security programs.

Annex 3 — Retention Schedule

  • Assistant chat logs, tour analytics events, quiz and feedback responses: 12 months, then deleted automatically.
  • Anonymous daily totals (counts only, with no identifiers or free text): for as long as the account is active.
  • Content and account data: for as long as the account is active.
  • Search index of knowledge base documents (Gemini File Search, only documents visible to visitors): each copy is removed after its document is deleted, archived or hidden from visitors, and the whole index is erased with the account.
  • Closed accounts: kept for 30 days so they can be restored, then erased. Backup copies are overwritten within 90 days of erasure.
  • After erasure: training completion records with the learner's name, email and IP removed, and certificates deleted, for up to 3 years. Billing records about the Customer itself (not its visitors or learners) are kept by DoBeacon as controller for 7 years.