The customer is the controller (or a processor acting for its own customer); Scaled Apps LLC is the processor, processing personal data only on the customer’s documented instructions — which are the Terms, this Addendum, and the customer’s use and configuration of the Services.
| Service | Personal data | People | Kept |
|---|---|---|---|
| authto.it | email address or mobile number, name, role, sign-in times, hashed IP, browser | the customer’s site users | until the customer removes them; activity 90 days |
| mapto.it | phone locations, stops, arrival/departure events, device labels | the customer’s staff or contractors who install the app | raw locations 14 days (never shown); stops up to 180 days; events up to 30 days; shorter if the customer sets it |
| sendto.it | email messages and attachments (any content), sender and recipient addresses | senders and recipients of mail to the customer’s inboxes | content 7 days, records 30 days |
| saveto.it | whatever the archived documents contain | as in the documents | while tracked; versions kept per plan |
| thumbto.it | whatever the rendered pages or files contain | as in the content | a thumbnail until unused for 365 days (its resized copies 30 days); uploaded files deleted after rendering |
| offto.it | scan times, hashed IP, browser | people who scan codes | per plan: 30 days to 5 years |
| pingto.it | alert email addresses and phone numbers | the customer’s staff | while the account exists |
| all | account members’ names and emails (via ScaledApps ID) | the customer’s team | while the account exists |
ScaledApps may use these subprocessors, and will give 30 days’ notice of a new one (by email to account owners), during which the customer may object and cancel:
| Subprocessor | Purpose | Data |
|---|---|---|
| Microsoft (Microsoft 365 / Graph) | sending notification and sign-in emails | recipient addresses, message content |
| Microsoft (Azure Communication Services) | sending authto.it sign-in text codes | phone numbers, codes |
| Twilio | sending pingto.it text alerts | phone numbers, alert text |
| Stripe | billing and tax | billing contacts, payment data (held by Stripe) |
| OpenStreetMap Foundation | map tiles in the customer’s browser (mapto.it) | the map area being viewed and the viewer’s IP — not stops or locations |
The Services run on servers and devices operated by ScaledApps in the United States (including Raspberry Pi devices at several US sites that probe websites, receive mail and render thumbnails).
Data is processed in the United States. For customers in the EEA, UK or Switzerland, the parties rely on the EU Standard Contractual Clauses (module 2, or module 3 where the customer is itself a processor) and the UK International Data Transfer Addendum, which are incorporated by reference.