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Data Processing Agreement

Document Reference: GEO-SPEC-001 · System Architecture Version: 2.0 (Pure Prompt Inversion Model) · Effective Date: July 3, 2026

This Data Processing Agreement (“DPA”) supplements the VerifiedLayer Terms of Service and forms a legally binding data privacy contract between VerifiedLayer (“Processor”) and the verified corporate entity claiming its profile or licensing intent data via the platform (“Controller”).

1. Background and Applicability

1.1: Context of Data Transfer

The Controller utilizes VerifiedLayer’s platform services, including accessing the verified Vendor Dashboard and receiving high-intent B2B user data generated via VerifiedLayer’s Contextual Intent Trigger Model.

1.2: Data Framework Roles

In the course of delivering these services, VerifiedLayer may transfer personal information (such as Buyer/Evaluator names, corporate emails, professional titles, and contextual query metadata) to the Controller once a User has provided explicit, affirmative consent via the platform’s content gate. Under applicable Data Protection Legislation (including EU GDPR, UK GDPR, and CCPA/CPRA), the software Vendor acts as an independent Data Controller for their licensed lead pipeline, and VerifiedLayer acts as the Data Processor orchestrating the matching interface.

2. Definitions

  • “Data Protection Legislation” means all global data privacy laws applicable to the processing of personal data under this agreement, including the EU General Data Protection Regulation (2016/679), the UK Data Protection Act 2018, and United States state-level privacy acts (such as the California Consumer Privacy Act/California Privacy Rights Act).
  • “Personal Data” means any information routed to the Controller via the platform that relates to an identified or identifiable natural person (specifically enterprise buyers, reviewers, or evaluators passing through the Consent-Gated Content Wall).
  • “Sub-processor” means any third-party data hosting, security infrastructure, or API management service engaged by VerifiedLayer to assist in the processing of account data or lead routing.

3. Scope and Details of Processing

3.1: Subject Matter

The processing of user-level registration details, administrative vendor credentials, and high-intent contextual B2B lead profiles.

3.2: Duration

The term of this DPA shall run concurrently with the Controller’s active registration, profile claim status, or data licensing contract on VerifiedLayer.

3.3: Nature and Purpose

To enable secure identity validation for Vendor Representatives managing profiles (/company/{slug}), and to legally transfer validated, contextually triggered B2B intent leads to the Controller once a platform User has actively authorized disclosure in exchange for premium competitive metrics.

3.4: Categories of Data Subjects

  • Registered platform Buyers, Evaluators, and Reviewers.
  • Authorized Vendor Representatives and corporate administrators.

3.5: Type of Personal Data

First and last names, corporate email addresses, job titles, employer/company names, platform interaction history (e.g., specific alternative platforms evaluated), and explicit user consent time-stamps.

4. Obligations of the Processor (VerifiedLayer)

VerifiedLayer warrants that it will handle all system-level personal data in strict compliance with the following parameters:

4.1: Processing Limitations

VerifiedLayer shall process personal data solely in accordance with documented instructions from the Controller, including configurations established within the authenticated Vendor Dashboard, unless strictly required to do otherwise by applicable international law.

4.2: Personnel Confidentiality

VerifiedLayer ensures that all technical personnel, database engineers, and platform administrators authorized to manage or route the underlying data pipelines have signed binding non-disclosure agreements or are subject to appropriate statutory obligations of confidentiality.

4.3: Technical and Organizational Security Controls

VerifiedLayer implements robust security architectures to shield the account registration databases and lead-routing pipelines from unauthorized access, modification, or exposure. These encompass:

  • Forced Transport Layer Security (TLS) encryption for all data in transit.
  • Advanced AES-256 cryptographic encryption for data stores at rest.
  • Role-based access control structures limiting system access to authorized platform engineers.
  • Web Application Firewall (WAF) rule sets designed to detect and block automated API flooding or extraction scripts.

5. Obligations of the Controller (The Software Vendor)

As an independent recipient and controller of the B2B Contextual Intent Leads routed by VerifiedLayer, you explicitly covenant and agree to the following legal terms:

5.1: Adherence to User Opt-Outs and Deletions

If an enterprise User requests account deletion or executes a downstream privacy right with VerifiedLayer, VerifiedLayer will transmit an automated downstream data modification signal to the Controller. Upon receipt of this signal, the Controller must immediately scrub, delete, or modify that User’s corresponding Personal Data within its internal marketing, CRM, or sales databases, unless an independent statutory regulation requires preservation.

5.2: Mandatory Purpose Limitation

The Controller agrees to process the licensed B2B intent leads solely for legitimate, targeted professional outreach relevant to the specific product categories or competitive comparisons the User was investigating at the moment of the Contextual Trigger event. Broad, indiscriminate spam distribution or selling these leads onward to unverified third-party marketing networks is strictly prohibited.

6. Sub-processors

6.1: Authorized Engagement

The Controller grants VerifiedLayer general authorization to engage infrastructure sub-processors (such as cloud database providers, identity verification services, and security networks) to host the Site and maintain lead-routing queues.

6.2: Contractual Flow-Down

VerifiedLayer shall impose data protection obligations upon any engaged sub-processor that are no less restrictive than those set out in this DPA, ensuring an unbroken chain of enterprise data protection.

7. Audits and Compliance Demonstration

VerifiedLayer shall make available to the Controller all technical documentation and administrative logs necessary to demonstrate compliance with the data security obligations laid out in this DPA. If requested under regulatory oversight, VerifiedLayer will cooperate with independent data protection audits executed to confirm the operational validity of the platform’s Consent-Gated Content Wall.

8. Liabilities and Indemnification

The Controller agrees to defend, indemnify, and hold harmless VerifiedLayer against any legal actions, administrative fines, regulatory penalties, or consumer lawsuits arising from the Controller’s misuse, unauthorized disclosure, or unlawful processing of the B2B Contextual Intent Leads once they have been successfully transferred from VerifiedLayer’s platform to the Controller’s internal system environments.

9. Governing Law

This DPA shall be governed by, interpreted, and enforced under the exact choice of law and jurisdictional provisions set forth in the VerifiedLayer Terms of Service (the laws of the State of Delaware, United States).