Data Processing Agreement (DPA)

1. Parties

Controller: The municipality or organization identified in the order form or onboarding documents (“Controller”).

Processor: MuniGrowth (“Processor”), contact@munigrowth.com.

This DPA supplements the Terms of Service and Privacy Policy when Controller is subject to GDPR or similar laws.

2. Subject Matter and Duration

Processor processes personal data on behalf of Controller to provide the MuniGrowth LED planning and grant intelligence platform. Processing continues for the subscription term and for a post-cancellation retention period (including export and reactivation windows) as described in the Privacy Policy, unless law requires longer retention.

3. Nature, Purpose, and Categories

Nature: hosting, storage, retrieval, AI-assisted analysis, export generation, support.

Purpose: LED planning, grant workflows, collaboration, billing, security.

Categories of data subjects: municipal employees, contractors, and officials authorized by Controller.

Types of personal data: identification, contact, professional role, usage logs, content entered into the Platform, AI interaction logs.

4. Obligations of Processor

Processor shall:

• Process personal data only on documented instructions from Controller, including regarding transfers;
• Ensure personnel are bound by confidentiality;
• Implement appropriate technical and organizational security measures (see Trust page);
• Assist Controller with data subject requests within reasonable timeframes;
• Notify Controller without undue delay of personal data breaches;
• Delete or return personal data at termination, subject to legal retention;
• Make available information necessary to demonstrate compliance and allow audits upon reasonable notice.

5. Sub-processors

Controller authorizes the following categories of sub-processors (current list):

• OpenRouter — AI inference routing (USA);
• Dodo Payments — payment processing;
• Sentry — application error monitoring;
• Infrastructure hosting — VPS provider in Lebanon (or successor region notified in advance).

LibreTranslate is operated self-hosted on Processor infrastructure and is not an external translation SaaS sub-processor.

Processor will notify Controller of new sub-processors with reasonable notice; Controller may object on documented grounds.

6. International Transfers

Where personal data is transferred outside the EEA/UK, parties will execute Standard Contractual Clauses or rely on another lawful mechanism as advised by legal counsel.

7. Liability

Liability under this DPA is subject to the limitations in the main Terms unless mandatory law provides otherwise. Each party remains responsible for its own regulatory obligations.

8. Execution

This DPA becomes effective when signed by both parties or when Controller executes the online acceptance provided by MuniGrowth.