Data Controller vs Processor Roles
In the context of the Data Processing Agreement, Evokaro acts as a data processor while its clients serve as data controllers. This means that Evokaro processes personal data on behalf of its clients, who determine the purposes and means of processing the data.
Personal Data Processed
Evokaro processes various types of personal data, which may include:
- Contact information (e.g., names, email addresses, phone numbers)
- Demographic data (e.g., age, gender, location)
- User-generated content (e.g., comments, feedback)
- Behavioral data (e.g., browsing history, engagement metrics)
Purpose and Legal Basis
The primary purpose of processing personal data by Evokaro is to deliver digital marketing solutions, including:
- Targeted advertising
- Performance analytics
- Customer relationship management
The legal basis for processing personal data includes the necessity of processing for the performance of a contract, compliance with legal obligations, and legitimate interests pursued by the data controller.
Sub-processors
Evokaro may engage sub-processors to assist in the processing of personal data. A list of approved sub-processors is maintained, and clients will be notified of any changes. Sub-processors are required to adhere to the same data protection obligations as outlined in this agreement.
Data Subject Rights
Data subjects have the following rights regarding their personal data:
- The right to access personal data
- The right to rectification
- The right to erasure (right to be forgotten)
- The right to restrict processing
- The right to data portability
- The right to object to processing
Evokaro will assist clients in fulfilling these rights in accordance with applicable data protection laws.
Data Transfer Safeguards
Evokaro ensures that any transfer of personal data outside the European Economic Area (EEA) is conducted in compliance with applicable data protection laws. This includes implementing Standard Contractual Clauses (SCCs) or other appropriate safeguards to protect personal data during international transfers.