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Data Processing Addendum

UNIVERSALHOMEANDTECH LTD · Company no. 16534780 · ICO registration ZC044007 · Last updated 4 July 2026

1. Roles

For personal data contained in end-customer conversations, the business using Torbie is the data controller and UNIVERSALHOMEANDTECH LTD ("Torbie") is the data processor. This addendum forms part of our Terms of Service.

2. Scope of processing

Torbie processes conversation content, visitor identifiers and any details visitors provide, solely to deliver the chat service on the controller's instructions.

3. Sub-processors

We use vetted infrastructure and AI-model sub-processors to operate the service. Data is not used to train third-party AI models. A current list is available on request.

4. Security

Row-level data isolation per business, encryption in transit, signed connector access limited to allowlisted fields, and access controls. See our Security page for detail.

5. Data subject rights & deletion

Controllers can export or erase any customer's data at any time from their dashboard, and can delete their entire account. We assist with data-subject requests as required by law.

6. International transfers

Where data is transferred across borders, we rely on appropriate safeguards such as standard contractual clauses.