Data Processing Terms (DPA)

Incorporated into the ClientFoyer Terms of Service (Section 15) and published at clientfoyer.com/dpa on adoption.

1. Roles. For Client Data, you are the controller/business and we are your processor/service provider. For Account Data, our Privacy Policy governs our processing as controller.

2. Instructions. We process Client Data only on your documented instructions — these Terms, your and your authorized users' and agents' use of the service (including portal and intake configuration and API/MCP calls), and your written requests — or where required by law (we will inform you unless prohibited). If we believe an instruction violates data-protection law, we will tell you.

3. Purpose limitation. We will not sell Client Data, use it for our own marketing, or use it to train AI models, and we will not retain, use, or disclose it outside providing the service.

4. Confidentiality. Persons authorized to process Client Data are bound by confidentiality.

5. Security. We maintain the measures described in the Privacy Policy's Security section, appropriate to the nature of the data (N.Y. SHIELD Act reasonable safeguards).

6. Subprocessors. You authorize the providers listed below. We require each to protect data under written terms, we remain responsible for them, and we will give at least 30 days' notice of additions or replacements by email or by posting to this page. If you object on reasonable data-protection grounds and we cannot resolve it, you may terminate the affected account and receive a pro-rata refund of prepaid unused fees.

Current subprocessors (Client Data):

  • Stripe, Inc. — subscription billing (receives your billing identity and subscription state; client payment links are yours, not processed by us).
  • Resend, Inc. — transactional email delivery (receives recipient addresses and message content needed to deliver notifications you trigger).
  • ImprovMX — inbound mail forwarding for our @clientfoyer.com addresses.
  • Google LLC (Gmail) — hosts our support mailbox (receives support correspondence you send us).
  • Meta Platforms, Inc. (Muse) — AI assistant used by the operator for support and operations under the operator's direction (receives support correspondence, which may include Client Data, when the operator works support tasks); a training opt-out is in effect, so information processed through it is not used to train AI models.
  • PostHog, Inc. — product analytics (receives account-holder usage events and session-replay data with all form inputs masked; replay is disabled on the client portal and public invoice pages; invoice events carry the invoice number and amount but no client names or contact details).
  • Microsoft Corporation (Clarity) — public-page analytics only (receives visit data from the homepage, pricing, blog, and legal pages; it is not present in the signed-in service and receives no Client Data).
  • Cloudflare, Inc. — network routing and TLS termination via Cloudflare Tunnel (traffic between visitors and the service transits Cloudflare's network; processes connection metadata, including visitor IP addresses, to deliver and secure that traffic; does not store Client Data at rest).

Website analytics (GoatCounter) is hosted by us and is not a subprocessor. The service runs on infrastructure we operate; there is no third-party hosting provider.

7. Assistance. Taking into account the nature of the service, we will assist you — through the export, correction, and deletion tools in the service, and on written request — to respond to your clients' rights requests, and will promptly forward to you any such request we receive directly.

8. Breach notice. We will notify you without undue delay, and in any event within 72 hours after becoming aware of a personal-data breach affecting Client Data, with the information then available, and will cooperate in investigation and remediation.

9. End of service. Client Data is available for export at any time while your account is open. On account closure we delete Client Data under the retention schedule in the Privacy Policy, subject to legal retention; on written request before closure we will return or delete it as you instruct.

10. Information. On reasonable written request we will provide information reasonably necessary to demonstrate compliance with these terms. (For a self-serve service, this does not include on-site audits.)

Annex. Subject matter: providing hosted client portals, file sharing, intake forms, invoicing links, and testimonials. Duration: the subscription term plus the deletion period in the Privacy Policy. Data subjects: your clients and contacts. Categories: identifiers, contact details, form responses, files and their contents, comments, approval records, invoice and payment-status data, testimonials.

These terms assume the service is offered to users in the United States only (Terms of Service, Section 1). If EU/UK users are ever admitted, counsel must add the standard contractual clauses / UK addendum by reference before these terms are offered to them.