Corom

Draft — under legal review. Not yet in effect.

Data Processing Addendum

Effective date to be announced · Version 2026-10-11-us-uk-draft

A summary of the Data Processing Addendum (DPA) that governs how the Company processes personal information in our Customers’ records. It forms part of our Terms of Service. The full DPA is available on request.

Who does what

The Customer is the controller of the personal information in its records (a “business” under US state laws). The Company is its processor (a “service provider” or “processor”), and processes that information only on the Customer’s documented instructions. The DPA is written to meet Article 28 of the UK GDPR and the processor and service-provider rules of US state privacy laws such as the CCPA and the Colorado Privacy Act.

The processing

ItemDetails
Subject matterProviding the Service: a records system for recycling facilities and brokers.
DurationWhile the Customer uses the Service, and until its data is deleted afterwards (within 30 days).
Nature and purposeStoring, displaying, adding up and reporting on records; reading text from uploaded files on our own servers; signing users in; support.
Personal informationNames, work emails and roles of users; names of people who key or correct records, with their reasons; names and details of drivers, haulers and contacts at suppliers, buyers and disposal sites, as entered or contained in uploaded documents and photos; network addresses and sign-in records.
People concernedThe Customer’s users (employees and contractors), and people named in its records and documents.
Sensitive informationNone intended. Customers are asked not to upload it.

What we commit to

Transfers from the United Kingdom

Customer data is stored in the United States. For UK Customers, the DPA includes the UK International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses as the safeguard for that transfer.

Getting the full DPA

The full DPA, ready to sign, is available on request. Ask at the Contact page.