Data Processing Addendum

This page summarises the LearnSys Data Processing Addendum (DPA) that supplements our Master Subscription Agreement with B2B tenants. It is provided to support enterprise procurement and due-diligence reviews.

Overview

Where LearnSys processes personal data on behalf of a Tenant, the Tenant is the “data controller” and iGears Technology Limited is the “data processor”. The DPA sets out:

• The subject matter, duration, nature, and purpose of processing.
• Categories of data subjects (operators, students, parents/guardians) and personal data.
• Confidentiality obligations on personnel.
• Technical and organisational security measures (Annex II).
• Sub-processor engagement, notification, and objection rights (Annex III).
• Assistance with data-subject requests and breach notification within 72 hours of becoming aware.
• Audit rights and certifications.
• International transfer safeguards (Standard Contractual Clauses where applicable).
• Return and deletion of personal data on termination.

Scope

The DPA applies to all personal data processed by LearnSys on the Tenant's instructions, including data submitted through the web app, mobile apps, and APIs. It is governed by the laws of Hong Kong unless a Tenant's regulatory regime requires otherwise (e.g., GDPR for EU/EEA tenants).

Sub-processors

The current list of sub-processors is published in our Privacy Policy. We will give Tenants at least 30 days' notice before adding or replacing a sub-processor.

Download

A downloadable PDF of the standard DPA template is available on request: [DPA PDF — TODO upload to /storage/legal/learnsys-dpa.pdf].

Request an executed DPA

To request an executed DPA, or to discuss bespoke amendments, email [email protected] with your Tenant name and the regulatory regimes that apply (e.g., GDPR, UK GDPR, PDPO, CCPA).

Postal: iGears Technology Limited, #307, 9488 51 Avenue, Edmonton, AB, T6E 5A6, Canada.

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