Last updated: 9th September 2025
This Data Processing Agreement (“Agreement”) is entered into between:
(1) Controller: The Retailer or organisation subscribing to and using the Glazing Bot service.
(2) Processor: THiNK! Creations Ltd, registered in England & Wales, Company No. 13144028, registered office at Unit M1 Mosquito Studios De Havilland Court, Penn Street, Amersham, England, HP7 0PX (“THiNK! Creations”).
This Agreement forms part of the Subscription Terms & Conditions for the use of Glazing Bot and governs the processing of personal data carried out in connection with the service.
1. Subject Matter and Duration
- THiNK! Creations will process personal data on behalf of the Controller in connection with the provision of Glazing Bot.
- The Agreement will remain in force for the duration of the Controller’s subscription and until all personal data is deleted or returned in accordance with this Agreement.
2. Nature and Purpose of Processing
THiNK! Creations will process personal data for the following purposes:
- Capturing, storing, and transmitting consumer chat conversations.
- Collecting and forwarding consumer contact details (email, phone number) submitted via the Bot.
- Maintaining conversation logs for quality assurance and AI evaluation.
- Providing account, billing, and subscription records.
3. Types of Personal Data and Data Subjects
- Personal Data: Free-text chat messages, names, phone numbers, email addresses, billing contact details, and other personal information voluntarily submitted by end-users.
- Data Subjects: End customers of the Controller (consumers who interact with GlazingBot).
4. Processor Obligations
THiNK! Creations shall:
- Only process personal data on documented instructions from the Controller.
- Ensure confidentiality of persons authorised to process personal data.
- Implement appropriate technical and organisational measures to protect data (including authenticated access, encryption in transit, secure hosting).
- Assist the Controller with data subject rights requests (access, rectification, erasure, portability).
- Notify the Controller without undue delay of any personal data breach.
- Support the Controller in carrying out Data Protection Impact Assessments (DPIAs) where required.
5. Sub-Processors
- THiNK! Creations uses third-party service providers for hosting, AI evaluation, and payment processing.
- The Controller authorises THiNK! Creations to engage these and other sub-processors, provided adequate safeguards are in place.
6. International Data Transfers
Where personal data is transferred outside the UK/EEA (e.g. to AI or hosting providers), THiNK! Creations shall ensure appropriate safeguards are applied, such as the UK Addendum to the EU Standard Contractual Clauses.
7. Data Retention and Deletion
- Chat logs are retained for the duration of the Controller’s subscription unless otherwise requested.
- Upon termination, all personal data will be deleted within 90 days, unless longer retention is required by law.
8. Audit Rights
The Controller has the right to request information necessary to demonstrate compliance. On reasonable notice, THiNK! Creations will provide evidence of compliance measures or allow audits (subject to confidentiality and cost recovery).
9. Liability
Each party shall be responsible for its own compliance with data protection laws. Liability is subject to the limitations set out in the main Subscription Terms.
10. Governing Law
This Agreement is governed by the laws of England and Wales, and the parties submit to the exclusive jurisdiction of the English courts.
Acceptance By subscribing to and using Glazing Bot, the Controller acknowledges and agrees to the terms of this Data Processing Agreement.