Data Processing Agreement
Last updated: April 12, 2026
This DPA supplements the Terms of Service and Privacy Policy and applies to customers on paid plans who need a data processing agreement for their own compliance requirements.
1. Parties and Definitions
This Data Processing Agreement ("DPA") is entered into between:
- "Controller" — You, the customer, who determines the purposes and means of processing personal data obtained through the Service
- "Processor" — NewSiteLead, which processes data on your behalf as part of delivering the Service
"Personal Data" means any information relating to an identified or identifiable natural person, as defined by applicable data protection law (including GDPR, CCPA/CPRA, and similar frameworks).
2. Scope and Purpose of Processing
NewSiteLead processes data on your behalf for the following purposes:
- Providing domain intelligence data via web interface and API
- Generating AI-powered Diagnostic Reports for domains you specify
- Delivering transactional emails related to your account and purchases
- Enforcing subscription plan limits and usage tracking
Categories of Data Processed
| Category | Data Elements | Retention |
|---|---|---|
| Account data | Email, hashed password, Stripe customer ID | Until account deletion + 30 days |
| Login history | IP address, timestamp | 12 months |
| Usage logs | API calls, searches, exports, page views | 12 months |
| Diagnostic data | Domain, business context notes, generated reports | 200 days (auto-deleted) |
| Payment data | Stripe customer/subscription IDs (no card numbers) | Until account deletion |
3. Processor Obligations
NewSiteLead shall:
- Process personal data only on documented instructions from the Controller, unless required by law
- Ensure that persons authorized to process personal data are bound by confidentiality obligations
- Implement appropriate technical and organizational security measures (see Section 5)
- Not engage additional sub-processors without prior notice to the Controller (see Section 4)
- Assist the Controller in responding to data subject rights requests (access, rectification, erasure, portability)
- Delete or return all personal data upon termination of the service, at the Controller's choice, subject to legal retention requirements
- Make available all information necessary to demonstrate compliance with this DPA
4. Sub-Processors
NewSiteLead uses the following sub-processors:
| Sub-Processor | Purpose | Data Processed | Location |
|---|---|---|---|
| Stripe, Inc. | Payment processing | Email, payment details | United States |
| Anthropic PBC | AI report generation | Domain name, business context notes | United States |
| MXroute | Transactional email delivery | Recipient email, email content | United States |
| Contabo GmbH | Infrastructure hosting | All data at rest | United States |
We will notify active subscribers by email at least 14 days before adding a new sub-processor. If you object to a new sub-processor, you may terminate your subscription before the change takes effect.
5. Security Measures
NewSiteLead implements the following technical and organizational measures:
- Encryption in transit: All data transmitted via HTTPS/TLS 1.2+
- Encryption at rest: Database and backup storage on encrypted volumes
- Access control: SSH key-based authentication, no shared credentials, principle of least privilege
- Password security: Bcrypt hashing with per-user salts; API keys stored as SHA-256 hashes
- Network security: Firewall rules (nftables) restricting access to internal services; Cloudflare WAF on public endpoints
- Monitoring: Automated bot detection and blocking; login anomaly tracking
- Backups: Regular automated backups with encrypted offsite storage
- Vendor security: Sub-processors selected based on their own security posture and compliance certifications
6. Data Breach Notification
In the event of a personal data breach, NewSiteLead shall:
- Notify the Controller without undue delay and no later than 72 hours after becoming aware of the breach
- Provide details of the breach: nature, categories of data affected, approximate number of records, likely consequences, and measures taken or proposed to mitigate
- Cooperate with the Controller in investigating and remediating the breach
- Document the breach and remediation steps taken
7. Data Subject Rights
NewSiteLead will assist the Controller in fulfilling data subject requests including:
- Access: Providing copies of personal data held
- Rectification: Correcting inaccurate data
- Erasure: Deleting data (available via account dashboard or by request)
- Portability: Exporting data in machine-readable format
- Restriction/Objection: Limiting or ceasing processing upon valid request
Requests should be directed to contact@newsitelead.com. We aim to respond within 15 business days.
8. International Data Transfers
All data processing occurs within the United States. NewSiteLead and all sub-processors are U.S.-based. If you are subject to GDPR or similar frameworks requiring specific transfer mechanisms, please contact us to discuss applicable safeguards (e.g., Standard Contractual Clauses).
9. Audit Rights
Upon reasonable written request (no more than once per calendar year), the Controller may request information about NewSiteLead's data processing practices and security measures to verify compliance with this DPA. NewSiteLead will provide written responses to audit questionnaires within 30 business days. On-site audits are not supported, but we will cooperate with reasonable alternative verification methods.
10. Term and Termination
This DPA is effective for the duration of your subscription. Upon termination:
- Account data is deleted within 30 days of account deletion
- Diagnostic Reports are auto-deleted after their 200-day retention period
- Login history and usage logs are purged per the retention schedule in Section 2
- We may retain data as required by law or to resolve disputes
11. Governing Law
This DPA is governed by the same terms as the Terms of Service — the laws of the State of California, with disputes resolved per the dispute resolution procedures in the ToS.
12. Contact
For DPA-related inquiries, data subject requests, or breach notifications:
NewSiteLead
25422 Trabuco Rd STE 184
Lake Forest, CA 92630
contact@newsitelead.com