Data Processing Agreement

Last updated: 8 October 2026

This Data Processing Agreement ("DPA") forms part of the agreement between Tavon Partners Ltd, trading as Tavons (the "Processor", "we"), and the business that uses Tavons (the "Controller", "you"). It applies whenever we process personal data on your behalf. It is intended to meet Article 28 of the UK GDPR. It takes effect when you create your account.

1. Who is responsible for what, in short

You (Controller)We (Processor)
Decide why and how personal data about your leads, clients, contacts and referrers is usedOnly process it to provide Tavons, following your documented instructions
Have a lawful basis (and any consent) for collecting and contacting people, and give them privacy informationKeep it confidential and secure, and limit access to people who need it
Comply with PECR and honour opt-outs and objectionsHelp you answer data subject requests and tell you quickly about a breach
Decide what to keep, correct or delete using the controls in TavonsDelete or return data when the service ends
Keep your users' credentials secureUse only sub-processors listed here, under equivalent terms

2. Definitions

"Personal data", "controller", "processor", "data subject", "processing", "personal data breach" and "supervisory authority" have the meanings in the UK GDPR and the Data Protection Act 2018 ("Data Protection Law"). "Customer Data" means the personal data we process for you under the agreement.

3. Details of the processing

Subject matterProviding the Tavons CRM and related services to the Controller
DurationFor as long as the Controller has a Tavons account, plus the deletion period in section 11
Nature and purposeHosting, storing, organising, displaying, emailing and deleting Customer Data to provide the CRM, calendar, journey planning, card scanning, statement checking, referral and email features
Types of personal dataNames, business names, phone numbers, email addresses, postal and business addresses, location of businesses, notes and meeting details, deal and product details, referral details, and user account details. We do not need, and you must not enter, special category data or criminal offence data.
Data subjectsThe Controller's leads, prospects, clients, contacts, referrers and its own staff and users

4. Our obligations as Processor

We will:

5. Sub-processors

You give us general authorisation to use the sub-processors listed in Annex 2. We will put in place a written contract with each that provides equivalent data protection obligations, and we remain responsible for them. We will give you at least 14 days' notice (by email to your administrator or a notice in the portal) before adding or replacing a sub-processor. You may object on reasonable data protection grounds within that time; we will then work with you in good faith, and if the issue cannot be resolved you may cancel without penalty and receive a refund of any prepaid fees for the period after cancellation.

6. Data subject requests

If a data subject contacts us about Customer Data, we will not respond except to say we have passed it to you, unless the law requires us to. We will send it to you within 5 working days. Tavons includes tools for you to find, correct, export and delete records; if you need our help beyond those tools, we will provide it within a reasonable time, and may charge reasonable costs for unusually large requests.

7. Personal data breaches

We will tell you without undue delay, and in any case within 48 hours of becoming aware of a personal data breach affecting Customer Data. Our notice will say, as far as we know: what happened, the type and approximate amount of data and people affected, the likely consequences, and what we are doing about it. We will keep you updated, help you meet your duty to notify the Information Commissioner (within 72 hours) and affected people where required, and will not tell regulators or data subjects about a breach affecting your data without telling you first, unless the law requires it.

8. Assessments and consultation

We will give you reasonable help with data protection impact assessments and with consulting the supervisory authority, where they relate to our processing.

9. Audits

You may ask us for information to show compliance with this DPA (for example our security overview and sub-processor details), and we will answer within a reasonable time. If that is not enough, you may carry out an audit, no more than once a year unless there has been a breach, on 30 days' written notice, during working hours, without disrupting the service, subject to confidentiality, and at your own cost. We may meet an audit request by providing recent independent audit reports or certifications held by us or our sub-processors.

10. International transfers

We keep Customer Data in the UK or Europe where we can. If a sub-processor transfers Customer Data outside the UK, we will make sure the transfer is covered by a UK adequacy regulation, the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, or another lawful safeguard.

11. Deletion and return

You can export or delete Customer Data yourself while your account is open. When your account ends we will keep Customer Data for 30 days so you can retrieve it, then delete it from our live systems, and it will fall out of backups on their normal cycle (within 35 days after that). On request we will confirm deletion in writing. We may keep personal data we are required by law to keep, and will keep it protected and not use it for any other purpose.

12. Your responsibilities

You confirm that you have a lawful basis, and where needed consent, for the Customer Data you give us and for the messages you send; that you have given data subjects the information required by law; and that your instructions comply with Data Protection Law. You are responsible for the security of your users' passwords and devices, and for setting your users' access appropriately.

13. Liability

Each party's liability under this DPA is subject to the limits and exclusions in the Terms of Service (section 12), and counts towards the cap there. Nothing in this DPA limits liability that cannot lawfully be limited, or any liability a data subject can claim directly under Data Protection Law. As between us, each party is responsible for compensating the other, to the extent allowed by law and subject to the cap, in proportion to its share of responsibility for a claim.

14. Term, changes and law

This DPA lasts as long as we process Customer Data for you. We may update it to reflect changes in law or in the service, with 30 days' notice. It is governed by the law of England and Wales, and the courts of England and Wales have jurisdiction. Questions: support@tavons.com.

Annex 1: Security measures

Annex 2: Sub-processors

Sub-processorPurposeLocation
SupabaseDatabase, authentication and file storageEurope (project region shown in your account)
NetlifyWebsite and application hosting and serverless functionsGlobal edge network
RenderStatement analysis and Google connection services[confirm region]
ResendSending emails on your behalf[confirm region]
Google (Maps Platform, Calendar, Contacts, sign-in)Address search, route planning, optional calendar and contacts connectionsGlobal
Text-recognition providerReading business card images[confirm provider and region]
Payment provider (when subscriptions are enabled)Taking payments; we do not store full card numbers[confirm]