Data Processing Addendum

The Customer is the controller: it decides which features to use and so what personal data is collected and why. QR Gate is the processor and processes that data only for the Customer. Two records are QR Gate's own (returning-visitor recognition and photo ID check results), as described in the Privacy Policy; this addendum doesn't cover them.

• Subject matter and purpose: managing entry to the Customer's spaces — verifying phones, applying the Customer's rules, opening doors or showing codes, keeping the record — and the features the Customer turns on (members, passes, waivers, photo ID checks, texts, the staff clock, park bookings, events).
• People: the Customer's visitors, members, guests, staff, park and event guests, and the people on its team.
• Data: phone numbers (as keyed one-way codes and last 4 digits; in full only where the Privacy Policy says), names, emails, visit records, waiver signatures, staff hours and, where allowed, GPS at a punch, and IP address and browser type. Photo ID images are handled by Stripe Identity and never reach QR Gate.
• Duration: while the Customer's account exists, then as in section 8.

QR Gate processes the data only on the Customer's instructions: these Terms, the settings it chooses in the dashboard and app, and its written requests. If the law requires other processing, QR Gate tells the Customer first unless the law forbids it. QR Gate never sells the data or uses it for advertising.

Only QR Gate staff who need to — to run the service or answer the Customer — can reach the data, under a duty of confidentiality. Each time QR Gate staff open an organization's data it is logged, and their accounts require two-factor sign-in.

• Encryption in transit (HTTPS/TLS) everywhere.
• Door codes, lock-account tokens, calendar addresses, and the full phone numbers kept outside a member list (remembered phones, text subscribers, staff, park and event guests) encrypted at rest (AES-256-GCM, rotatable keys).
• Phone numbers otherwise stored as keyed one-way codes; passwords, API keys and link tokens only as one-way hashes.
• Two-factor sign-in available to every owner and required for QR Gate staff, for the Customer's operators, and for an owner with a team.
• Each organization's data kept separate and reachable only by its own account and team.
• A changes log of who changed what, kept 2 years and never editable.
• Encrypted backups stored apart from the servers; dependencies scanned for known vulnerabilities.

The Customer authorizes the sub-processors listed in the Privacy Policy, each with only what its job needs, under that company's own data-protection terms. QR Gate stays responsible to the Customer for their work. Before adding or replacing one, QR Gate updates that list and emails account holders; a Customer that objects on reasonable data-protection grounds may end its account.

• People's requests: QR Gate helps the Customer answer requests to see, correct or delete data, and passes on any request it receives about the Customer's data.
• Breaches: QR Gate tells the Customer within 72 hours of becoming aware of a breach affecting its data — what happened, what data and people are involved, what QR Gate has done, and a contact — and keeps it informed.
• Assessments and audits: QR Gate provides the information reasonably needed to show it meets this addendum, including answering a security questionnaire once a year.
• Legal requests: as in the Privacy Policy — only for a valid subpoena, warrant or court order, only what's named, and the Customer told first unless a court forbids it.

QR Gate keeps the data for the periods below, deleting it automatically. When the Customer deletes its organization (Settings), everything it holds is deleted after a 7-day undo window; encrypted backups age out within 35 days. Before then the Customer can export its records as CSV from the dashboard.

QR Gate is offered to organizations in the United States; it isn't offered in the European Union or the United Kingdom.

This addendum applies without a signature. A Customer that needs a signed copy prints this page, signs below and emails it to privacy@qrgate.app; QR Gate countersigns and sends it back.