Clonvara Insurance Services - Data Processing Agreement (signed)
Documentexecuted Clonvara Insurance Services: documents · dpa · executed · 2025-10-17
Executed Data Processing Agreement under the MSA, signed 17 Oct 2025. Clonvara Insurance Services is controller and B-Brain processor, with data staying in the customer's own Snowflake account. It states no price, availability or response times.
What it says
What this says
Current to 11 Oct 26Executed Data Processing Agreement under the MSA, signed 17 Oct 2025. Clonvara Insurance Services is controller and B-Brain processor, with data staying in the customer's own Snowflake account. It states no price, availability or response times.
What it is: an executed DPA, version 1, that forms part of the Master Services Agreement. It covers personal data about brokers, policyholders, claimants and the customer's staff.
Commits: B-Brain to process data "only to provide the service and only on the Customer's instructions", to report breaches "without undue delay", and to allow "reasonable audits by the Customer, on notice and during normal working hours".
Unusual: no sub-processor may be engaged "without the Customer's authorisation". Return or deletion is at the customer's choice on ending of the services.
Not settled: no price, service levels, breach notification deadline, retention period or renewal date. The customer signatory is shown only as "Authorised signatory", with no name or role.
As found in this document
Current to 9 Oct 26- Date signed17 Oct 2025Source: object_read:doc_025_006
- Processing instructionsProcess personal data only to provide the service and only on the Customer's instructions.Process personal data only to provide the service and only on the Customer's instructions. · Source: object_read:doc_025_006
- Breach notificationTell the Customer without undue delay if B-Brain becomes aware of a personal data breach affecting the Customer's data.Tell the Customer without undue delay if B-Brain becomes aware of a personal data breach affecting the Customer's data. · Source: object_read:doc_025_006
- Sub-processorsB-Brain will not engage another processor for the Customer's personal data without the Customer's authorisation.B-Brain will not engage another processor for the Customer's personal data without the Customer's authorisation. · Source: object_read:doc_025_006
- Auditallow reasonable audits by the Customer, on notice and during normal working hours.allow reasonable audits by the Customer, on notice and during normal working hours. · Source: object_read:doc_025_006
- Return and deletionOn ending of the services, B-Brain will, at the Customer's choice, return or delete personal data it holds, unless the law requires it to be kept.On ending of the services, B-Brain will, at the Customer's choice, return or delete personal data it holds, unless the law requires it to be kept. · Source: object_read:doc_025_006
- Data locationCustomer data remains in the Customer's Snowflake account.Customer data remains in the Customer's Snowflake account. · Source: object_read:doc_025_006
The document
Body
Unusual terms
Current to 9 Oct 26- Sub-processors need customer authorisation
- Breach notice without undue delay, no fixed deadline
- Customer audit rights on notice