Legal
Data Processing Addendum
Version 2026-11-04 · Effective 2026-11-04
This addendum is part of the Terms of Service between the customer (the "Operator") and iter8.42 AI Labs, doing business as TraxKey AI ("TraxKey"). If it conflicts with the Terms on personal data, this addendum controls.
1. Roles
The Operator is the controller of personal data it places in the Service (or the "business" under California law). TraxKey is the processor (or "service provider"). TraxKey is the controller only for its own account, billing and website data, as the Privacy Policy describes.
2. What is processed
Purpose: to provide the Service to the Operator. Duration: while the account is active, plus the 30-day export period in the Terms. Data: names, email addresses, phone numbers, addresses, messages, and booking, lease, maintenance and invoice records. People: the Operator's residents, guests, owners, vendors and staff.
3. Instructions
TraxKey processes personal data only on the Operator's documented instructions: the Terms, this addendum, and the settings the Operator chooses in the Service. TraxKey tells the Operator if it believes an instruction breaks the law.
4. Confidentiality
People at TraxKey who can access personal data are bound by confidentiality duties.
5. Security
TraxKey keeps reasonable safeguards, including encryption in transit, role-based access control, separation of each customer's data, logging, and backups.
6. Sub-processors
The Operator agrees to the sub-processors listed in section 4 of the Privacy Policy. TraxKey binds each to data-protection terms that are no less protective. TraxKey posts changes to the list at least 14 days before they take effect. The Operator may object on reasonable data-protection grounds by emailing support@traxkey.ai.
7. Help with requests
TraxKey gives the Operator the tools and reasonable help it needs to answer requests from individuals to access, correct, delete or export their data, and to carry out data protection assessments. If an individual contacts TraxKey directly, TraxKey refers them to the Operator.
8. Incidents
If TraxKey confirms that personal data in its control was accessed or disclosed without authorisation, it tells the Operator without undue delay and within 72 hours of confirming it, with the information it has that the Operator needs to meet its own duties.
9. Return and deletion
The Operator can export its data at any time while the account is active. After termination TraxKey keeps the data for 30 days for export, then deletes it, except records the law requires TraxKey to keep and backups that expire on their normal cycle.
10. Audits
On reasonable written request, no more than once a year, TraxKey gives the Operator the information needed to show compliance with this addendum. The parties start with documents and written answers.
11. Transfers
The Service is for businesses in the United States, and data is processed in the United States. If personal data from the EEA or UK is ever in scope, the Standard Contractual Clauses apply as the parties agree in writing.
12. California
TraxKey is a service provider. It does not sell or share personal information, and does not retain, use or disclose it outside the business purpose of providing the Service or as the law allows.
13. Contact
See also our Terms of Service and Privacy Policy.