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Legal

Data Processing Agreement

In effect from 11 September 2026

Effective Date: 16-08-2026

This Data Processing Agreement ("DPA") forms part of the agreement between Wastify AI Ltd (company number 16641783, ICO registration ZB957060, "Wastify", "we", "us") and the customer named in the applicable order or Master Services Agreement ("Customer"), and applies wherever Wastify processes personal data on the Customer's behalf in the course of providing the Wastify AI platform, hardware and related services (the "Services").

1. Roles

For personal data processed within the Services, the Customer is the controller and Wastify is the processor. Wastify acts as a controller only for its own business administration, such as billing contacts and account records.

2. Scope of processing

  • Subject matter: provision of the Wastify AI waste management platform and associated hardware.
  • Duration: the term of the agreement, plus the deletion period in section 9.
  • Nature and purpose: recording, storing and reporting waste data captured in the Customer's buildings, including the operation of weighing hardware, photographic evidence, automated image analysis to identify and classify waste, reporting and analytics.
  • Categories of data subjects: the Customer's staff and contractors who use the platform, building occupier staff, and individuals incidentally captured in photographic evidence.
  • Categories of personal data: names, work contact details, user account records, activity logs, and photographs taken in waste areas which may incidentally include images of individuals.
  • Special category data: none is required by the Services and the Customer agrees not to submit any.

3. Instructions

Wastify processes personal data only on the Customer's documented instructions, including as set out in the agreement and the configuration choices the Customer makes in the platform, unless required to do otherwise by law. If Wastify believes an instruction infringes data protection law, it will inform the Customer without undue delay.

4. Confidentiality

Wastify ensures that persons authorised to process the personal data are bound by appropriate obligations of confidentiality.

5. Security

Wastify implements appropriate technical and organisational measures to protect personal data, as described in the Security Policy published on this site. Measures include encryption in transit, access controls, environment separation and logging.

6. Sub-processors

The Customer gives general written authorisation for the engagement of the sub-processor categories listed in the Sub-processors document published on this site. Wastify will give the Customer prior notice of the addition or replacement of a sub-processor, allowing a reasonable opportunity to object, and remains responsible for its sub-processors' performance.

7. Data subject rights

Taking into account the nature of the processing, Wastify will assist the Customer with appropriate technical and organisational measures to respond to requests from data subjects exercising their rights under UK data protection law.

8. Personal data breach

Wastify will notify the Customer without undue delay after becoming aware of a personal data breach affecting the Customer's personal data, and will provide the information reasonably required for the Customer to meet its own notification obligations.

9. Return and deletion

On termination or expiry of the Services, Wastify will, at the Customer's choice, return or delete the personal data processed on the Customer's behalf within 90 days, unless retention is required by law. Verified waste records may be retained in anonymised or aggregated form that no longer identifies any individual.

10. Audit

Wastify will make available the information reasonably necessary to demonstrate compliance with this DPA and will allow for and contribute to audits, including inspections, conducted by the Customer or an auditor mandated by the Customer, on reasonable notice and no more than once in any 12 month period unless required by a supervisory authority.

11. International transfers

Personal data is processed in the United Kingdom or the European Economic Area wherever practicable. Where a transfer to another country is necessary, Wastify ensures an appropriate safeguard under UK data protection law is in place, such as the UK International Data Transfer Agreement or Addendum.

12. Contact

Questions about this DPA should be sent to hello@wastify-ai.co.uk.