In the event that Lineage Lines Studio is engaged by a business entity, medical facility, or memory care center (the “Client”) to process personal data of residents or third parties, this Data Processing Agreement shall apply to ensure compliance with applicable data protection laws.
1. Scope and Role Definitions
- Definitions: “Personal Data” refers to any information relating to an identified or identifiable individual. “Processing” refers to any operation performed on personal data (e.g., image conversion, storage).
- Roles: The Client acts as the Data Controller, and Lineage Lines Studio acts as the Data Processor.
- Subject Matter: The processing of personal photographs into line-art coloring pages for the purpose of reminiscence activities.
2. Obligations of the Processor
Lineage Lines Studio agrees to:
- Instruction-Based Processing: Process personal data only on documented instructions from the Client, unless required by law.
- Confidentiality: Ensure that all personnel authorized to process the personal data have committed themselves to confidentiality.
- Security Measures: Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk (e.g., encrypted file transfers and secure local storage).
3. Sub-Processing
- Authorized Sub-Processors: The Client grants general authorization for Lineage Lines Studio to engage third-party sub-processors for specialized tasks (e.g., cloud storage and third-party professional printing).
- Liability: Lineage Lines Studio remains fully liable to the Client for the performance of the sub-processor’s data protection obligations.
4. Data Subject Rights
Lineage Lines Studio shall assist the Client, insofar as this is possible, for the fulfillment of the Client’s obligation to respond to requests for exercising the data subject’s rights (e.g., access, rectification, or deletion of photos).
5. Incident Management & Breach Notification
In the event of a confirmed personal data breach, Lineage Lines Studio shall notify the Client without undue delay after becoming aware of the breach, providing sufficient information to allow the Client to meet any recovery or notification obligations.
6. Deletion or Return of Data
Upon termination of the service or at the Client’s request, Lineage Lines Studio shall delete or return all personal data to the Client and delete existing copies unless applicable law requires storage of the personal data.