Data Processing Agreement

Last Updated: July 2026

1. Introduction

This Data Processing Agreement ("DPA") forms part of the agreement between BalanceBit Solutions ("Data Processor" or "Processor") and the Client ("Data Controller" or "Controller") for the provision of digital services.

This DPA applies when BalanceBit Solutions processes personal data on behalf of the Client in the course of providing services. It sets out the terms and conditions under which the Processor shall process personal data on behalf of the Controller, in compliance with applicable data protection laws.

2. Definitions

• Personal Data: Any information relating to an identified or identifiable natural person that is processed by the Processor on behalf of the Controller.
• Processing: Any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction.
• Data Subject: An identified or identifiable natural person whose personal data is processed.
• Sub-processor: Any third party engaged by the Processor to process personal data on behalf of the Controller.
• Applicable Data Protection Laws: All laws and regulations applicable to the processing of personal data under this agreement, including but not limited to GDPR, CCPA, PIPEDA, and Pakistan's Personal Data Protection Act (when enacted).

3. Scope and Purpose of Processing

3.1 Subject Matter

The Processor processes personal data as necessary to provide the agreed digital services, including web development, mobile app development, cloud services, cybersecurity, AI solutions, digital marketing, creative design, and business support.

3.2 Duration

Processing continues for the duration of the service agreement between the parties, plus any additional period required for data return or deletion.

3.3 Nature and Purpose

Personal data is processed for the following purposes:

• Delivery of contracted services and project management
• Communication with the Controller and authorized users
• Technical support and maintenance
• Analytics and performance reporting (as agreed)
• Compliance with legal obligations

4. Processor Obligations

The Processor shall:

• Process personal data only on documented instructions from the Controller.
• Ensure that personnel authorized to process personal data are bound by confidentiality obligations.
• Implement appropriate technical and organizational security measures (see Section 7).
• Not engage sub-processors without prior written authorization from the Controller.
• Assist the Controller in responding to data subject requests (see Section 6).
• Assist the Controller in ensuring compliance with data protection obligations, including breach notification and impact assessments.
• Upon termination, return or delete all personal data, at the Controller's choice.
• Make available all information necessary to demonstrate compliance and allow for audits.

5. Controller Obligations

The Controller shall:

• Ensure it has a lawful basis for processing personal data.
• Provide documented processing instructions to the Processor.
• Ensure that data subjects have been informed of the processing as required by applicable law.
• Respond to data subject requests in a timely manner.
• Notify the Processor of any changes to its processing instructions.

6. Data Subject Rights

The Processor shall assist the Controller in fulfilling data subject rights, including:

• Right of Access: Providing copies of personal data held by the Processor.
• Right to Rectification: Correcting inaccurate personal data.
• Right to Erasure: Deleting personal data when instructed by the Controller.
• Right to Restriction: Limiting processing of personal data.
• Right to Data Portability: Providing personal data in a structured, machine-readable format.
• Right to Object: Ceasing processing upon the Controller's objection.

Requests from data subjects should be directed to the Controller. The Processor will assist as reasonably required and will not respond directly to data subjects without the Controller's authorization, unless required by law.

7. Security Measures

The Processor shall implement the following technical and organizational measures:

7.1 Technical Measures

• Encryption of personal data in transit (TLS 1.2+) and at rest (AES-256).
• Regular security assessments and vulnerability scanning.
• Firewall protection and intrusion detection systems.
• Secure backup and disaster recovery procedures.
• Access controls with multi-factor authentication for sensitive systems.
• Regular patching and updating of software and systems.

7.2 Organizational Measures

• Data protection training for all personnel handling personal data.
• Background checks for personnel with access to sensitive data (where permitted by law).
• Documented data handling procedures and policies.
• Regular internal audits of data protection practices.
• Incident response procedures for data breaches.

8. Sub-processors

8.1 Authorized Sub-processors

The Controller authorizes the Processor to engage the following sub-processors:

• Hosting Providers: For website and application hosting (e.g., cloud infrastructure providers).
• Email Service Providers: For transactional and marketing email delivery.
• Payment Processors: For processing payments (if applicable).
• Analytics Providers: For website and application analytics (if applicable and agreed).

8.2 New Sub-processors

The Processor shall notify the Controller in writing at least 30 days before engaging any new sub-processor. The Controller may object to the engagement within 14 days of notification. If the Controller objects and the parties cannot resolve the objection, either party may terminate the affected services.

8.3 Sub-processor Obligations

The Processor shall ensure that all sub-processors are bound by data protection obligations no less protective than those in this DPA.

9. Data Breach Notification

In the event of a personal data breach:

• The Processor shall notify the Controller without undue delay and no later than 48 hours after becoming aware of the breach.
• The notification shall include: nature of the breach, categories and approximate number of data subjects affected, likely consequences, and measures taken or proposed to address the breach.
• The Processor shall cooperate with the Controller in investigating the breach and mitigating its effects.
• The Processor shall not notify data subjects directly without the Controller's prior authorization, unless required by law.

10. Data Transfers

The Processor shall not transfer personal data to countries outside the Controller's jurisdiction without:

• Prior written authorization from the Controller.
• Implementation of appropriate safeguards (e.g., standard contractual clauses, binding corporate rules).
• Verification that the receiving country provides adequate data protection.

Current processing locations: Pakistan (primary), with cloud infrastructure in regions selected by the Controller.

11. Data Retention and Deletion

• The Processor retains personal data only for as long as necessary to provide the services.
• Upon termination of the service agreement, the Processor shall, at the Controller's choice, return or delete all personal data within 30 days.
• The Processor shall provide written confirmation of deletion upon request.
• The Processor may retain copies as required by applicable law, subject to the confidentiality obligations of this DPA.

12. Liability and Indemnification

Each party shall be liable for damage caused by processing that violates applicable data protection laws. The Processor shall indemnify the Controller against claims arising from the Processor's failure to comply with this DPA or applicable data protection laws.

13. Term and Termination

This DPA shall remain in effect for the duration of the service agreement and for as long as the Processor holds any personal data on behalf of the Controller. The obligations under this DPA survive termination for a period of 3 years.

14. Governing Law

This DPA shall be governed by the laws applicable to the Controller's jurisdiction, with particular reference to data protection legislation. Disputes shall be resolved in accordance with the dispute resolution provisions of the main service agreement.

15. Contact

For questions about this DPA or data processing practices, contact:

BalanceBit Solutions
Data Protection Contact: support@balancebitsolutions.com
Phone: +92 318 714 3324
Website: https://balancebitsolutions.com