Data Processing Agreement

Last updated: June 8, 2026 — Version 1.0

This Data Processing Agreement ("DPA") supplements the ScanMyHomes Terms of Service and applies when Horizon Digital Group LLC ("ScanMyHomes," "Processor") processes personal data on behalf of a customer ("Controller") in the course of providing the Services.

1. Roles

The Controller determines the purposes and means of processing. The Processor processes personal data only on documented instructions from the Controller and as described in the Services.

2. Subject matter & duration

Processing relates to operating the ScanMyHomes platform — lead capture, listing publication, QR analytics, and related services — for the duration of the Controller's subscription.

3. Categories of data subjects & data

Data subjects: site visitors, leads, agents, and admin users. Data categories: contact details, listing engagement, device/usage data, and consent records.

4. Security measures

The Processor implements appropriate technical and organizational measures, including encryption in transit and at rest, role-based access controls, least privilege, audit logging, and incident response. See our Trust & Security page.

5. Sub-processors

The Controller authorizes the Processor to engage sub-processors (e.g., cloud hosting, email delivery, payments). A current sub-processor list is available on request from dpo@scanmyhomes.com.

6. International transfers

Where personal data is transferred outside the EEA, UK, or Switzerland, transfers are protected by Standard Contractual Clauses or another lawful transfer mechanism.

7. Data subject rights

The Processor will assist the Controller in responding to data subject requests via reasonable technical and organizational measures. End users may also submit requests directly via the Consumer Rights Center.

8. Breach notification

The Processor will notify the Controller without undue delay (and no later than 72 hours where feasible) after becoming aware of a personal data breach.

9. Return or deletion

Upon termination, the Processor will return or delete personal data, subject to retention required by law.

10. Audits

The Processor will make available information reasonably necessary to demonstrate compliance with this DPA and applicable law.

Contact

For DPA execution or questions, email dpo@scanmyhomes.com.