Data Processing Agreement (DPA)
This Data Processing Agreement ("DPA") forms part of the Cyclesite Terms of Service and applies to the processing of personal data by TPSTORES LIMITED (trading as Cyclesite) on behalf of users in accordance with the UK General Data Protection Regulation (UK GDPR, being the EU GDPR as retained in UK law by the European Union (Withdrawal) Act 2018) and the Data Protection Act 2018.
1. Definitions
In this DPA:
- "Controller" means the natural or legal person which determines the purposes and means of processing personal data
- "Processor" means a natural or legal person which processes personal data on behalf of the controller
- "Data Subject" means an identified or identifiable natural person
- "Personal Data" means any information relating to an identified or identifiable natural person
- "Processing" means any operation performed on personal data
2. Roles and Responsibilities
For the purposes of this DPA:
- Cyclesite acts as a Data Controller for platform operations and user accounts
- Users (sellers and buyers) act as Data Controllers for their own listing data and communications
- Cyclesite may act as a Data Processor when processing data on behalf of dealers and business users
3. Scope of Processing
Cyclesite processes personal data for the following purposes:
- User account management and authentication
- Facilitating communication between buyers and sellers
- Processing transactions and payments
- Providing analytics and reporting services
- Preventing fraud and ensuring platform security
- Complying with legal obligations
4. Data Categories
The personal data processed may include:
- Identity data (name, username, email address)
- Contact data (phone number, address, postcode)
- Technical data (IP address, browser type, device information)
- Transaction data (payment details, purchase history)
- Usage data (page views, interactions, preferences)
- Marketing data (communication preferences)
5. Data Subject Rights
Data subjects have the following rights under UK GDPR:
- Right to access their personal data
- Right to rectification of inaccurate data
- Right to erasure ("right to be forgotten")
- Right to restriction of processing
- Right to data portability
- Right to object to processing
- Rights related to automated decision-making
6. Security Measures
Cyclesite implements appropriate technical and organizational measures including:
- Encryption of data in transit (HTTPS/TLS)
- Encryption of sensitive data at rest
- Access controls and authentication
- Regular security audits and penetration testing
- Employee training on data protection
- Incident response procedures
7. Sub-Processors
Cyclesite may engage the following categories of sub-processors:
- Cloud hosting providers (AWS, Google Cloud)
- Payment processors (Stripe)
- Email service providers
- Analytics platforms
- Customer support tools
A current list of sub-processors is available upon request.
8. Data Transfers
Personal data may be transferred to and processed in countries outside the UK and EEA. Where such transfers occur, Cyclesite ensures adequate safeguards are in place through:
- Standard Contractual Clauses (SCCs)
- Adequacy decisions by relevant authorities
- Binding Corporate Rules
9. Data Retention
Personal data is retained only for as long as necessary:
- Active user accounts: Duration of account + 6 months
- Transaction records: 7 years (legal requirement)
- Marketing data: Until consent is withdrawn
- Technical logs: 90 days
10. Data Breach Notification
In the event of a personal data breach, Cyclesite will:
- Notify the ICO within 72 hours where required
- Notify affected data subjects without undue delay if high risk
- Document all breaches and remedial actions
- Cooperate with regulatory authorities
11. Audit Rights
Controllers have the right to audit Cyclesite's data processing activities upon reasonable notice and subject to confidentiality obligations.
12. Termination
Upon termination of services:
- Personal data will be returned or deleted as requested
- Deletion will occur within 30 days unless legal retention applies
- Certificates of deletion can be provided upon request
13. Liability and Indemnification
Each party shall be liable for damages caused by processing in violation of data protection obligations to the extent permitted by law.
14. Governing Law
This DPA is governed by English law and UK data protection law, including the UK GDPR and the Data Protection Act 2018.
Contact
For questions about this DPA or data processing practices, please contact our Data Protection Contact at:
Email: support@cyclesite.co.uk
This DPA supplements our Privacy Policy and forms part of our overall commitment to data protection and GDPR compliance.