Data Processing Agreement (DPA) By Bluez Innovations LLC 

Last Updated: March 18, 2025 

1. Introduction 

At Bluez Innovations LLC, we take data protection seriously. This Data Processing Agreement (DPA) outlines how we process personal data on behalf of our clients while ensuring compliance with General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable privacy laws. 

This agreement clarifies both parties’ obligations and sets guidelines for the responsible handling of personal data. 

By using our services, the Client acknowledges and agrees to the terms outlined in this DPA. 

2. Definitions 

To ensure transparency, the following key terms apply to this Agreement: 

Controller – The Client, who determines the purposes and means of processing personal data. 

Processor – Bluez Innovations LLC, who processes personal data on behalf of the Controller. 

Personal Data – Any information related to an identifiable individual that is processed under this Agreement. 

Processing – Any operation performed on personal data, including collection, storage, modification, and deletion. 

Sub-Processor – Any third-party service provider engaged by the Processor to assist in processing personal data. 

3. Scope and Purpose of Processing 

At Bluez Innovations LLC, we process personal data strictly to provide high-quality digital marketing, AI-powered automation, SEO, and website development services to our clients. 

3.1 Nature of Processing 

We process personal data as necessary to deliver our digital solutions, which may include: 

  • Website tracking, analytics, and performance improvements. 
  • AI-driven marketing automation for customer engagement. 
  • Secure data storage and management for project execution.

3.2 Types of Data Processed 

Depending on the services provided, we may process: 

  • Basic Identifiers – Name, email, phone number. 
  • Website Data – IP addresses, browsing behavior, cookie data. 
  • Customer Interaction Data – Messages, form submissions, chatbot interactions. 
  • Business Information – Data necessary for campaign execution and project management.

3.3 Purpose of Processing 

We process personal data strictly for: 

  • Delivering and improving our services. 
  • Managing client accounts and project execution. 
  • Ensuring legal and security compliance. 
  • Enhancing website functionality and customer engagement.

Through these defined purposes, we avoid using personal data in ways that fall outside our client engagements. 

4. Data Processing Responsibilities 

Both Bluez Innovations LLC (Processor) and the Client (Controller) have specific responsibilities in handling personal data securely and lawfully. 

4.1 Responsibilities of Bluez Innovations LLC (Processor) 

We commit to: 

  • Processing personal data only as instructed by the Client. 
  • Implementing technical and organizational measures to protect personal data. 
  • Notifying the Client promptly in the event of a data breach. 
  • Assisting with data subject requests (e.g., access, rectification, deletion). 
  • Restricting personal data access to authorized personnel only. 
  • Ensuring all employees or agents who process data are under a confidentiality obligation. 
  • Upon request and where feasible, deleting or returning all personal data to the Client after the end of service provision (except where retention is required by law).

4.2 Responsibilities of the Client (Controller) 

The Client is responsible for: 

Ensuring that all personal data shared with the Processor is lawfully obtained. 

  • Obtaining necessary user consent where applicable (for example, informing and getting permission from their customers to share data with us for processing). 
  • Providing processing instructions that comply with applicable laws. 
  • Informing the Processor of any specific data handling requirements resulting from the Client’s own obligations (e.g., if certain data must not leave a particular jurisdiction). 
  • Responding to data subjects’ inquiries or rights requests (the Processor will assist as needed, but the Controller holds the primary relationship with the individuals).

By working together under these guidelines, both parties can maintain compliance and protect data subject rights. 

5. Use of Sub-Processors 

To deliver services efficiently, we may engage third-party providers as Sub-Processors. 

  • We maintain an updated list of Sub-Processors (e.g., cloud hosting services, email delivery services) and can provide this list to the Client upon request. 
  • Bluez Innovations conducts due diligence to ensure Sub-Processors have appropriate data protection measures. 
  • If we plan to add or change Sub-Processors in a way that materially affects the processing of personal data, we will inform the Client and, if required, give an opportunity to object (for legitimate grounds related to data protection). 
  • We will have a contract with each Sub-Processor that imposes data protection obligations equivalent to those in this DPA, particularly with respect to implementing adequate technical and organizational measures.

The Processor remains fully liable to the Client for the performance of any Sub-Processor that fails to fulfill its data protection obligations. 

6. Data Security Measures 

We employ strong security measures to protect data from unauthorized access, disclosure, or alteration. These measures include: 

  • Encryption: Personal data may be encrypted in transit (e.g., via SSL/TLS) and at rest, where appropriate. 
  • Access Controls: Access to personal data is limited to authorized personnel who require it for processing purposes. We use authentication mechanisms and, when possible, multi-factor authentication for sensitive systems. 
  • Physical Security: Systems and facilities used for data processing are secured (e.g., through the data centers of reputable cloud providers with robust physical security controls). 
  • Network Security: Firewalls, intrusion detection systems, and anti-malware tools are used to protect against external threats. 
  • Training: Staff handling personal data receive training on data protection and information security best practices. 
  • Audits and Testing: We periodically review our security policies and conduct testing (such as vulnerability scans or penetration tests) to ensure ongoing effectiveness of our security measures.

If the Client requires specific security measures (for example, compliance with an internal security policy or industry standard), the Client should communicate those requirements, and both parties will work to document and implement appropriate measures. 

7. Data Retention & Deletion 

We retain personal data only as long as necessary for service delivery or as required by law or the Client’s instructions. 

  • Duration of Processing: By default, we process and retain data for the duration of our service agreement with the Client. 
  • Upon Termination: Upon termination or expiration of services, and at the Client’s direction, we will delete or return all personal data provided by the Client, unless legal obligations require further retention. 
  • Deletion Process: When instructed to delete data, we will securely erase personal data from our systems (and instruct any Sub-Processors to do the same), except for backups archived on rotation. Backup data will continue to be protected under the terms of this DPA until overwritten or securely destroyed. 
  • Retention Exceptions: We may retain data if required for legitimate business interests such as fraud prevention or if necessary to comply with legal obligations (e.g., financial records retention) – but only in line with applicable laws and with appropriate protections in place.

The Client is responsible for retrieving any needed data before the end of the service term or instructing us if data should be returned at that time. 

8. Data Subject Rights 

We assist the Client in fulfilling data subject requests, including: 

  • Access: Providing confirmation if we process a data subject’s personal data and access to such data, when requested by the Controller. 
  • Rectification: Promptly correcting inaccurate or incomplete data upon instruction. 
  • Erasure: Deleting personal data upon valid request (and instructing Sub-Processors to do so) unless an exemption applies. 
  • Data Portability: If applicable, exporting personal data in a structured, commonly used format for transfer to the data subject or another controller. 
  • Objection/Restriction: Accommodating any justified requests to stop or limit processing (for example, suppressing a contact from marketing-related processing if asked).

The Client should communicate any data subject requests to Bluez Innovations with sufficient detail and within a reasonable timeframe to allow compliance. We will promptly inform the Client if we directly receive a data subject request related to the Client’s data (unless legally prohibited). 

9. Compliance with Applicable Laws 

This Agreement complies with: 

  • General Data Protection Regulation (GDPR): For clients or data subjects in the EEA/UK, we adhere to GDPR requirements as a processor, including assisting with lawful basis compliance and executing Standard Contractual Clauses (SCCs) for data transfers if needed. 
  • California Consumer Privacy Act (CCPA): For California data, we act as a “Service Provider” and do not sell personal information. We use data only for the purposes specified by the Client. 
  • Other Laws: We also observe other relevant privacy regulations (such as CAN-SPAM for email, HIPAA if applicable via separate addendum, etc.) to the extent they apply to our role and services.

The Client is responsible for ensuring that their use of Bluez Innovations’ services complies with laws applicable to them as a data controller (e.g., providing privacy notices, obtaining consents, honoring opt-outs). 

10. Limitation of Liability 

Bluez Innovations LLC shall not be liable for indirect or consequential damages related to obligations under this DPA, except to the extent not permitted by law. Our liability (taken together with that of our employees, agents, and Sub-Processors) for all claims arising from or related to this DPA is subject to the limitations and exclusions set forth in the main service agreement between the parties. 

Each party remains responsible for any fines or penalties imposed due to its own non-compliance with applicable data protection laws. 

11. Term & Termination 

11.1 Duration of the Agreement 

This DPA remains in effect as long as we process personal data on behalf of the Client (i.e., for the duration of our service relationship and until data is deleted or returned in accordance with this DPA). 

11.2 Termination 

Termination of the main service agreement between Bluez Innovations and the Client will trigger termination of this DPA. Upon termination, we will ensure that we carry out the Client’s instructions regarding the deletion or return of personal data as described in Section 7. 

Sections of this DPA that are necessary to interpret compliance (such as confidentiality, data security, and liability clauses) shall survive termination as applicable, ensuring continued protection of personal data even post-contract. 

12. Governing Law & Dispute Resolution 

This Agreement shall be governed by the laws of Texas, USA. Any disputes arising from this DPA will follow the dispute resolution and jurisdiction terms of the main service agreement between the parties. 

If no such terms exist, the parties agree to first attempt to resolve the matter through good-faith negotiations. If that fails, any unresolved disputes will be subject to the exclusive jurisdiction of the courts in Texas, USA, unless otherwise required by applicable data protection laws. 

Contact Information 

For any inquiries or issues related to data processing under this DPA, please contact: 

By engaging with our services, both parties agree to the terms of this Data Processing Agreement.