Data Processing Agreement (DPA)

1. Roles

Customer is the Controller for personal data uploaded into Silux Call (including call recordings, transcripts, contacts, voicemail). Silux Control UK Ltd T/A Silux Call is the Processor.

2. Subject matter and duration

Processing is for the purpose of delivering the Silux Call service for the term of the Customer's subscription, plus a 30-day post-termination wind-down.

3. Categories of data subjects and data

• Data subjects: end-users at the Customer, callers and called parties, voicemail leavers.
• Data categories: identification (name, email), contact (phone), audio (call recording), text (transcripts), traffic (CDR), payment (where the agent-assisted payment feature is enabled and tokenised by Stripe).

4. Sub-processors

Current list, by category. Customer is notified of changes 30 days before they take effect.

5. Technical & organisational measures

• TLS 1.2/1.3 in transit, AES-256 at rest, KMS for HIPAA tenants.
• SRTP+TLS for SIP at tenant request (`encryptionPolicy = require_srtp_tls`).
• Role-based access; the telephony management interface is reachable on loopback only.
• Recording redaction during PCI DTMF capture.
• Annual third-party penetration test; quarterly internal review.
• Audit log retained 6 years; immutable on HIPAA tenants.

6. International transfers

Where transfers occur outside the UK / EEA, we rely on the IDTA and the EU SCCs (Module 2: controller-to-processor) plus encryption.

7. Audit

Customer may audit Silux on 30 days' written notice, no more than once a year, except in the event of a confirmed breach.

8. Breach notification

We notify the Customer's registered admin within 24 hours of confirmed incidents.