Data Processing Addendum (DPA)
Typed By Hand (TBH) Data Processing Addendum (DPA)
This DPA is made between Typed by Hand (TBH) (“Processor”) and the School, District, or Educational Institution(“Controller”) that has entered into a Pilot Agreement, Terms of Service, or other service agreement with TBH (the “Main Agreement”).
This DPA is incorporated into the Main Agreement by reference. By using the TBH platform, the Controller agrees to be bound by these terms.
1. DEFINITIONS:
• “Student Data" means any personally identifiable information (PII) regarding a student provided to TBH by the Controller.
• “Sub-processor" means any third-party service provider used by TBH to help provide the Services (e.g., cloud hosting).
2. SCOPE AND ROLE
• Role of the Parties: The School is the "Controller" (owns the data) and TBH is the "Processor" (handles the data on behalf of the school).
• Compliance: TBH shall process Student Data only for the educational purposes of providing the "Authentically Human" verification service.
3. DATA SECURITY
• Protection: TBH shall implement appropriate technical and organisational measures, including AES-256 encryption at rest and in transit, to protect Student Data.
• Breach Notification: In the event of a security breach, TBH will notify the School within 48 hours of confirmation.
4. SUB-PROCESSORS
• Authorisation: The School authorises TBH to use the following Sub-processors:
• Google Cloud / AWS: Infrastructure and Hosting.
• Wyvern Innovations: Technical Development and Support.
• Notification: TBH will notify the School of any changes to the Sub-processor list via the TBH website.
5. STUDENT DATA RIGHTS (FERPA/COPPA)
• Access Requests: TBH will assist the School in responding to any parent or student requests to access, correct, or delete Student Data.
• Data Deletion: Upon expiry of the Pilot Period and unless a paid subscription is commenced, TBH will permanently delete all Student Data within 30 days.
6. FERPA & COPPA SPECIFICS
• School Official: TBH acknowledges it is a "School Official" with a legitimate educational interest under FERPA.
• COPPA Compliance: TBH will not use Student Data for any commercial purpose, including targeted advertising or building "user profiles" for non-educational use.