This Data Processing Addendum ("DPA") forms part of the Terms of Service between Citlali Technologies LLC, operator of the CitlaliBridge platform ("Processor"), and the organization or individual using the platform ("Customer" or "Controller").
CitlaliBridge Data Processing Addendum
This Data Processing Addendum forms part of the Terms of Service between Citlali Technologies LLC and the organization or individual using the CitlaliBridge platform, and governs the processing of Customer Data in connection with the platform services.
1. Definitions
Customer Data: Any data submitted to or processed by the CitlaliBridge platform by or on behalf of the Customer.
Processing: Any operation performed on Customer Data including collection, storage, organization, analysis, or deletion.
Subprocessor: A third-party service provider engaged by CitlaliBridge to process Customer Data.
2. Roles of the Parties
For the purposes of data protection, the Customer acts as the Controller of Customer Data, and Citlali Technologies LLC acts as the Processor of Customer Data.
CitlaliBridge processes Customer Data only on documented instructions from the Customer.
3. Scope of Data Processing
CitlaliBridge processes Customer Data solely to provide platform services including:
- Employer profile management
- Candidate profile management
- Sponsorship case management
- Compliance scoring and analytics
- Document storage and retrieval
- Audit logging and reporting
These capabilities correspond to the system modules that manage employer data, candidate records, case records, document storage, and scoring workflows within the platform architecture.
4. Types of Data Processed
Customer Data may include:
Employer Data
- Employer identifiers
- Sponsorship activity records
- Compliance indicators
Candidate Data
- Candidate identifiers
- Immigration case metadata
Document Data
- Uploaded supporting evidence
- Verification documents
System Metadata
- Audit logs
- Access logs
- Processing events
5. Processing Purpose
CitlaliBridge processes Customer Data solely for:
- Delivering platform functionality
- Generating compliance intelligence
- Maintaining audit traceability
- Supporting system security and monitoring
Customer Data is not used for advertising or sold to third parties.
6. Security Measures
CitlaliBridge implements reasonable administrative, technical, and organizational safeguards including:
- Role-based access controls
- Encrypted network communications
- Audit logging
- Infrastructure monitoring
- Controlled access to production systems
Security practices are designed to protect confidentiality, integrity, and availability of Customer Data.
7. Subprocessors
CitlaliBridge may use subprocessors to support platform operations, including cloud infrastructure providers.
Current categories of subprocessors include:
- Cloud hosting providers
- Infrastructure monitoring services
- Security monitoring services
CitlaliBridge remains responsible for ensuring subprocessors maintain appropriate data protection standards.
8. Data Retention
Customer Data will be retained only for as long as necessary to provide the platform services, maintain required audit logs, and comply with legal obligations.
Customers may request deletion of Customer Data upon termination of services, subject to applicable legal requirements.
9. Confidentiality
CitlaliBridge personnel who access Customer Data are subject to confidentiality obligations and are granted access only where necessary to perform their duties.
10. Data Breach Notification
If CitlaliBridge becomes aware of a confirmed unauthorized access or disclosure affecting Customer Data, CitlaliBridge will notify the Customer without undue delay after discovery.
Notifications will include available information about the nature of the incident and mitigation measures.
11. Customer Responsibilities
Customers are responsible for:
- Ensuring they have appropriate rights to submit Customer Data
- Complying with applicable data protection laws
- Ensuring that submitted data does not violate third-party rights
12. Deletion and Return of Data
Upon termination of services and written request, CitlaliBridge will delete or return Customer Data where feasible, except where retention is required for legal compliance or system integrity.
13. Governing Law
This Data Processing Addendum shall be governed by the laws of the State of Texas, United States.