Legal

Data Processing Addendum

Version 0.1 — DRAFT, NOT IN FORCE
Last updated: 5 August 2026

Not yet in force A DPA is a contract a customer's own lawyer will read line by line. This draft describes what the system genuinely does, which is the useful half. The legal construction must be done by counsel.

Purpose

This addendum applies where ConstructIQ processes personal data on behalf of a customer. It forms part of the Terms of Service. Where the two conflict on data protection, this addendum wins.

1. Roles

The customer is the controller. ConstructIQ is the processor. Sub-processors are listed in section 6.

ConstructIQ processes personal data only on the customer's documented instructions. Using the service as intended constitutes those instructions.

2. What is processed

Subject matterProvision of the ConstructIQ construction management platform
DurationFor as long as the customer holds an account, plus the retention period in section 8
NatureStorage, organisation, retrieval, transmission and deletion
Categories of data subjectCustomer staff; contractor and sub-contractor personnel; the customer's own clients
Categories of personal dataName, business email, phone number, role; site check-in location and time for crew; photographs taken on site; content of messages and site reports
Special category dataNone is required by the service. Note that incident reports may contain health information if the customer records injuries in them — see section 3.

3. Incident reports and health data

The service provides incident reporting for site accidents. If a customer records injury details, that is health data and attracts a higher standard of protection.

ConstructIQ does not require or request health data. Customers who record it are responsible for having a lawful basis to do so and for limiting who in their organisation can see it — the role permissions in the service allow that to be restricted.

4. Crew location data

Location is the most sensitive category the platform handles, and the controls are technical rather than promised:

Telling crew members that location is collected is the customer's responsibility as controller.

5. Security measures

Decision needed — what else to commit to Consider adding: backup and restore commitments (not yet configured on ConstructIQ production), a breach-notification window, penetration testing cadence, and personnel confidentiality undertakings. Only commit to what is actually in place.

6. Sub-processors

Sub-processorPurposeLocation
Google Cloud / FirebaseHosting, database, storage, authentication, push notificationsUnited States (us-east1)
AnthropicAI estimating and code-compliance assistanceUnited States
TwilioSMS and WhatsApp notifications United States
OpenWeatherMapWeather and storm alerts (site coordinates only, no personal data)Europe
Web Hosting CanadaOutbound email delivery Canada

ConstructIQ will give the customer prior notice of any new sub-processor handling personal data, and remains responsible for their performance.

7. International transfers

Personal data is stored in the United States. Customers and their personnel are typically in The Bahamas, so the service involves an international transfer.

Decision needed — transfer mechanism Confirm what the Bahamas Data Protection Act requires, and whether any prospective customer will require EU or UK standard contractual clauses. This section must name the mechanism, not describe the situation.

8. Return and deletion

The customer can export its data at any time while the account is active.

Decision needed — deletion timeline Set the export window after termination and the point at which data is deleted from live systems and from backups. Backups are not yet configured on ConstructIQ production; configure them before committing to a number.

9. Assisting the controller

ConstructIQ will provide reasonable assistance with:

Most individual requests can be answered by the customer directly, since administrators can view, edit, export and deactivate the records in their own workspace.

10. Personal data breach

Decision needed — notification window A number belongs here (24, 48 or 72 hours from becoming aware). Do not commit to one until there is monitoring capable of detecting a breach within it.

ConstructIQ will notify the customer without undue delay after becoming aware of a personal data breach affecting that customer's data, with the information needed for the customer to meet its own obligations.

11. Audit

ConstructIQ will make available the information reasonably necessary to demonstrate compliance with this addendum, and will contribute to audits carried out by the customer or an auditor it mandates, on reasonable notice and no more than once a year unless required by a regulator.

12. Acceptance

Decision needed — how this gets executed Decide whether the DPA is accepted by reference in the Terms, or signed separately. Enterprise customers will usually want a signed copy naming both entities.

13. Contact

support@constructiq.dev
Nassau, Commonwealth of The Bahamas