Data Processing Agreement — Ireland
The Article 28 terms under which Cerrax processes your customers' personal data on your instructions.
This agreement forms part of the Terms of Service and applies whenever Cerrax processes personal data on your behalf. It uses the meanings given in the GDPR (Regulation (EU) 2016/679) and the Data Protection Act 2018 (Ireland). Where this agreement and the Terms conflict on data protection, this agreement governs.
1. Which of us is which
You are the controller of the personal data you put into Cerrax or ask us to collect for you — about your customers, the people who enquire with you, your other contacts, and your staff and crew in their working role. We are your processor of it. We act on your instructions, and use that data for our own purposes only in the ways this agreement lists: making de-identified records (section 9); keeping descriptions of a job's items and rooms, with any email address, phone number or Eircode removed, for 30 days to improve how Cerrax recognises items (we keep no other text sent to our AI sub-processor); keeping the service secure and preventing abuse; and meeting our own legal obligations. For those, and only those, we are responsible as a controller. For your own account data — your team’s logins, your firm’s settings and billing — we are a controller in our own right, and our Privacy Policy covers that.
Your responsibilities. You are responsible for having a lawful basis for the personal data you give us or ask us to collect, for telling the people concerned about it (our Privacy Policy describes what we do, and you may point to it), and for any consent your messages need. You have the rights this agreement gives you.
No training exception here. Cerrax does not ask customers in Ireland to let it keep their video or photographs to train software, so everything in this agreement applies to them as it does to the rest of your customers' data.
2. What we process, and for how long
- Subject matter and purpose: running your removals business on Cerrax — receiving and organising your enquiries, keeping your customer records (contacts), pricing, quoting and following up quotes, booking and running jobs, and sending the messages you set up — all on your instructions.
- Nature of the processing: collecting, storing, organising, reading (including with AI, to suggest details for a person at your firm to confirm), pricing, sending messages on your behalf, de-identifying (section 9), exporting and deleting.
- Duration: for as long as your account is open, and afterwards only as section 8 allows.
- Type of personal data: names, addresses, contact details, move dates, and details of the property and its contents that you or your customer enter; where your crew use Cerrax on the day of the move, photographs of the property, its access and any damage found, together with the name and drawn signature of whoever signs the inventory off; and, where you invite it and your customer chooses to send them, a video of their home or photographs of it. Where you use them: your contacts (names, email addresses, phone numbers, company, preferred language, addresses used, the choices they gave you about your messages and when, where they came from, and your notes); enquiries, including the text of enquiry emails sent to your Cerrax lead address; the messages you send through Cerrax and whether they were delivered; follow-up tasks and their notes; whether a payment has been made (never card details); and reviews and ratings your customers give you.
- Categories of data subject: people who enquire with you (whether or not they become customers); your customers; the people at the properties you move between; other people you keep as contacts, such as landlords and letting agents; people named in notes, messages, photographs or video; and your staff and crew in their working role (assignments, job sheets, hours).
We do not ask for and do not want special-category data. Please do not enter health, biometric or similar information into free-text fields. If it arrives anyway — in an enquiry or a note — we hold it only as part of that record, never use it for pricing or learning, and keep it out of section 9.
A signature captured against an inventory is held as evidence that your customer agreed what was moved and in what condition. Nothing measures, compares or matches it, and it is never used to identify anyone — so we do not treat it as biometric data. Collecting signatures is optional: if you would rather your crew did not, simply do not use it.
3. We act on your instructions
We process your customers’ personal data only on your documented instructions — which include your use of the product and this agreement — unless Union or Member State law requires otherwise, in which case we will tell you first unless the law forbids that. Your instructions include instructions about transferring data outside the EU (section 13). If we think an instruction breaches data protection law, we will tell you promptly and may pause carrying it out until you confirm or change it.
Your instructions include these, when you use the features concerned: receiving emails sent to your Cerrax lead address and reading them — using our AI sub-processor where an email has no labelled layout — to suggest details you confirm; keeping contact records and the choices your customers make about your messages; and sending the reminder, thank-you and referral messages you switch on, in your name, honouring every request to stop at once and for all of those messages from you to that person. We keep a record of each choice and each stop, and a scrambled record of a stop for as long as it must be honoured.
Also on your instructions, when you use the features concerned: sending your customers the messages about a job that you set up (by WhatsApp where you have connected it, otherwise by email), including a review request and the private rating and comment a customer may give you; creating links you choose to share — a job sheet for your crew, or evidence (the customer's name, photographs, video and signatures, never their contact details) for your insurer, broker or claims handler; publishing your jobs to calendar subscriptions you create; and keeping follow-up tasks and their notes.
4. Confidentiality
Everyone we allow to access your customers’ personal data is bound by a written duty of confidentiality that continues after they leave, and only sees what their role requires. Access inside the product is governed by roles and individual permissions, checked on the server for every request.
5. Security
We take the technical and organisational measures Article 32 requires, described in our security overview — encryption in transit and at rest, role-based access control, an audit trail of consequential actions, point-in-time recovery and separate daily backups. That page states plainly what we do not yet have. We will not materially reduce the overall level of security described there while this agreement lasts.
6. Sub-processors
You give us general written authorisation to use sub-processors. The current list is in section 8 of our Privacy Policy and is kept current there. We impose data protection obligations on each of them no less protective than these, and we remain fully responsible to you for their performance. We will email your account owner at least 30 days before a new sub-processor starts handling your customers’ data (sooner only in an emergency, such as a provider failing, and then we tell you as soon as we can). You may object within that time on reasonable data protection grounds; if we cannot resolve it, you may end the affected service or your subscription and we will refund any fees paid in advance for the unused period. Services you connect yourself under your own account with them — your own Stripe, WhatsApp Business or Xero account — act on your instruction under your agreement with them, and are not our sub-processors.
If you subscribe your own calendar to your Cerrax calendar link, your calendar provider fetches your jobs under your own agreement with it; it is not our sub-processor.
7. Helping you meet your own obligations
Taking into account the nature of the processing, we will help you with requests from data subjects — access, correction, erasure, portability, objection — and with your duties under Articles 32 to 36 on security, breach notification and impact assessments. If a data subject contacts us directly about data we hold for you, we will refer them to you rather than answer for you. You can find, export, correct and delete a contact or a job yourself in the product; for anything the product cannot do, we will act within 10 working days of your written instruction. We will also pass on, and help you handle, any data protection complaint about data we process for you.
Breaches. If we become aware of a personal data breach affecting your data, we will tell you without undue delay and in any event within 48 hours — with what we know then, and the rest as we learn it: what happened, the data and people affected, the likely consequences, and what we are doing about it — so you can notify the Data Protection Commission within your 72 hours.
8. Deletion and return
Your instruction on how long we keep it. Unless you tell us otherwise, you instruct us to keep each job record — the quote, its booking and outcome, the crew's sheets and the photographs attached to them — for six years after the move (or after the quote, if the job did not go ahead), or for longer while a claim or dispute about that job is open, and then to delete it. A video, and any photographs your customer sends with it, are deleted 90 days after the job's last date. You can change this instruction by telling us.
Unless you tell us otherwise, you also instruct us to delete: an enquiry that was never priced or sent, 12 months after its last activity; a quote that was sent but never accepted, 24 months after it was sent; and a contact record 12 months after the last job record linked to it is deleted (or 12 months after it was made, if it was never linked to a job). A record of a person's consent is kept while their contact record is kept and for six years after; a scrambled record of a request to stop messages is kept for as long as it must be honoured.
When your subscription ends you can export your data for 30 days. We then delete your customers’ personal data within 90 days, and it leaves our backups as they expire (within 98 days), except where Union or Member State law requires us to keep it or you ask us to keep specific records, such as evidence in an open claim. Committed pricing records are never silently altered — personal identifiers within them are removed, which is how erasure is honoured without falsifying a record of what was quoted. Section 9 records are not your customers’ personal data and are not affected.
Two records keep their own periods: email delivery records (recipient, subject and whether it was delivered), 90 days; and the audit trail of actions in your account, up to six years after your account closes, with a customer's details removed when that customer is erased.
9. De-identified job data
(a) You instruct us to make de-identified records from the jobs we hold for you. (b) A de-identified record holds only the shape and economics of a job — volume, a distance band, access features, crew, vans, hours, price and cost, whether the quote was won and why not, the month of the move, and an area no finer than the first letter of the Eircode — and never a name, contact detail, full Eircode, address, map position, free text, photograph, video, signature, your firm's identity, or any reference that links it back to the job. (c) We treat a record as anonymous only when neither we nor anyone likely to receive it could, using means reasonably likely to be used, identify a living person from it, taking account of other information we or you hold. Data that can be linked back — for example by a job reference, or while we still hold the original job — is not anonymous and stays under this agreement until the original is deleted or its customer erased. (d) We will never try to re-identify anyone from these records, and will forbid anyone we share them with from doing so. (e) Once a record meets this standard it is not your customers’ personal data; it is ours, and we may keep and use it to improve and provide Cerrax, including after the underlying records are deleted and after this agreement ends. (f) We never show another firm, or anyone else, your individual prices or anything that identifies your firm.
10. Learning across firms
We use de-identified records under section 9, and statistics made from them, from across all firms using Cerrax, in every country, to improve the pricing engine for everyone, including you. This is stated here rather than assumed, because it is how the product gets better and we would rather you knew than found out.
11. Your numbers stay yours
Your rates, your margins, your customers and your prices are never visible to another firm, and never shown to the people you are quoting. The learning in section 10 runs on aggregated, de-identified signal — not on access to any one firm’s data by anybody else.
12. Audit
We will make available the information you reasonably need to show we are meeting these obligations — first by written answers and our security documentation — and will allow and contribute to an inspection by you or an auditor you appoint where those are not enough or a supervisory authority requires it: at your cost, on 30 days' notice, under confidentiality, without access to other firms' data, and no more than once a year unless a supervisory authority or a breach requires otherwise.
13. International transfers
We hold your customers’ personal data in the United Kingdom, in London. That is a transfer out of the European Union, and it is lawful because the European Commission has decided that the United Kingdom provides an adequate level of protection (Decision (EU) 2021/1772, renewed by Implementing Decision (EU) 2025/2574 of 19 December 2025 until 27 December 2031). You authorise it on that basis. Where a sub-processor processes data outside the EU and the UK, we rely on the EU–US Data Privacy Framework for providers certified to it, or otherwise on the EU standard contractual clauses (Decision (EU) 2021/914) with any supplementary measures the transfer needs; our Privacy Policy names the providers concerned. Where your data is stored on any given day is a question you can ask us at any time, and we will answer it for the day you ask.
Liability. Section 11 of the Terms of Service (limitation of liability) applies to this agreement.
14. Contact
Data protection questions, data subject requests and breach notifications: hello@cerrax.io.