EREG-Dialer
Working draft pending counsel review. Final wording locks before public launch.

Data Processing Addendum — EREG-Dialer

Working draft (2026-05-18). Counsel reviews. Replaces any prior version on execution.

This Addendum forms part of the Terms of Service between Elite Real Estate Group ("Processor") and the customer ("Controller") for the use of EREG-Dialer.

1. Definitions

"Personal Data" means data relating to identified or identifiable natural persons that Processor processes on behalf of Controller through EREG-Dialer.

2. Roles

Controller is the data controller of its tenant data, including contact records. Processor acts only on documented Controller instructions.

3. Processing details

  • Subject matter: telephony, CRM sync, billing, AI assistance, analytics.
  • Duration: lifetime of the subscription + retention period chosen by Controller.
  • Nature & purpose: outbound dialing and lead management.
  • Categories of data: contact name, phone, email, call records, dispositions, notes, recordings (where enabled).
  • Categories of data subjects: leads, prospects, and other contacts uploaded by Controller.

4. Security

Processor maintains administrative, technical, and physical safeguards as described in the Privacy Notice and Security pages.

5. Sub-processors

Listed at https://www.eregdialer.com/legal/sub-processors. Controller is notified at least 30 days in advance of changes with a right to object.

6. International transfers

For EU/UK data subjects, the EU Standard Contractual Clauses (Modules 2 and 3) and the UK Addendum apply and are incorporated by reference.

7. Data subject rights

Processor will assist Controller in responding to data-subject requests within 30 days.

8. Breach notification

Processor will notify Controller within 72 hours of becoming aware of a personal-data breach.

9. Audit

Once per year, on 30 days' notice, Controller may audit Processor's compliance, at Controller's expense, subject to confidentiality and reasonable scope limits.

10. Deletion

On termination, Processor deletes Personal Data within 90 days unless legal obligations require longer retention.

Working draft. Binding version executed with each enterprise customer.