1. Parties & Scope
This DPA is entered into between:
Processor: R Gupta Consultancy Services Inc., an Ontario corporation operating as GridOwl (“RGCS”), with offices in Ottawa, Ontario, Canada.
Controller: The organization identified in the GridOwl subscription agreement (“Customer”).
This DPA applies to all personal data that RGCS processes on behalf of the Customer through the GridOwl platform. It supplements and forms part of the Terms of Service. In the event of any conflict between this DPA and the Terms of Service, this DPA shall govern with respect to the processing of personal data.
2. Definitions
“Personal Data” means any information relating to an identified or identifiable natural person that RGCS processes on behalf of the Customer through the Service, as defined by the Personal Information Protection and Electronic Documents Act (PIPEDA).
“Processing” means any operation or set of operations performed on Personal Data, including collection, recording, organization, structuring, storage, adaptation, retrieval, use, disclosure, dissemination, restriction, erasure, or destruction.
“Data Breach” means a breach of security safeguards involving Personal Data that results in unauthorized access to, or unauthorized collection, use, disclosure, or disposal of, Personal Data.
“Sub-Processor” means any third party engaged by RGCS to process Personal Data on behalf of the Customer.
3. Details of Processing
Purpose of Processing
To provide the GridOwl temperature monitoring and HACCP compliance platform, including real-time sensor data ingestion, breach detection, automated alerting, compliance report generation, and audit logging.
Categories of Data Subjects
Customer employees and authorized users who access the GridOwl platform, including food safety managers, kitchen staff, and organization administrators.
Categories of Personal Data
Full name, email address, user role, activity logs (login times, actions taken), HACCP event acknowledgment/resolution records, and IP addresses.
Sensitive Data
GridOwl does not intentionally collect or process sensitive personal data (e.g., health, biometric, racial/ethnic origin). Temperature and sensor data is equipment-level data, not personal data.
Duration of Processing
For the term of the Customer’s subscription, plus the post-termination data export period (30 calendar days), plus any legally mandated retention periods for HACCP audit logs (minimum 2 years).
4. Controller Obligations
The Customer, as Controller, shall:
5. Processor Obligations
RGCS, as Processor, shall:
6. Security Measures
RGCS implements the following technical and organizational measures to protect Personal Data:
Encryption
Data encrypted in transit (TLS 1.2+) and at rest (AES-256). SMTP credentials and secrets encrypted with Fernet symmetric encryption. JWT tokens for authentication with configurable expiration.
Access Control
Role-based access control (RBAC) with four permission levels (Viewer, Editor, Tenant Admin, Super Admin). Row-level tenant isolation in PostgreSQL. 30 granular permissions across 10 resource categories.
Infrastructure
Hosted on AWS (Amazon Web Services) in Canada or US regions. ECS Fargate containers (no persistent server access). Cloudflare SSL termination and DDoS protection. Rate limiting per tenant.
Audit Trail
Immutable, hash-chained audit logs for all HACCP-critical actions. Activity logging for user actions. Webhook message deduplication for data integrity.
Password Security
Configurable password policies (minimum length, complexity requirements). Common password blocklist. Passwords hashed with industry-standard algorithms (bcrypt). NIST SP 800-63B compliant minimum floor of 8 characters.
7. Sub-Processors
The Customer grants RGCS general authorization to engage Sub-Processors to assist in providing the Service. RGCS shall:
Current Sub-Processors
| Sub-Processor | Purpose | Location |
|---|---|---|
| Amazon Web Services (AWS) | Cloud infrastructure & hosting | Canada / US |
| The Things Industries (TTI) | LoRaWAN network server | US (nam1 cluster) |
| Cloudflare | DNS, SSL, DDoS protection | Global (edge network) |
| PostHog | Product analytics (opt-in only) | US / EU |
8. Data Subject Requests
If RGCS receives a request from a data subject to exercise their rights under PIPEDA (access, correction, deletion, or withdrawal of consent), RGCS shall:
9. Data Breach Notification
In the event of a Data Breach, RGCS shall:
10. International Data Transfers
Personal Data is primarily processed in Canada and the United States. Where Personal Data is transferred outside of Canada:
11. Audit Rights
RGCS shall make available to the Customer all information reasonably necessary to demonstrate compliance with this DPA:
12. Data Return & Deletion
Upon termination or expiry of the Customer’s subscription:
13. Liability
Each party’s liability under this DPA is subject to the limitations of liability set forth in the Terms of Service. For clarity:
14. Term & Termination
This DPA shall remain in effect for the duration of the Customer’s subscription to the GridOwl Service. Sections that by their nature should survive termination shall survive, including Sections 6 (Security Measures), 9 (Data Breach Notification), 11 (Audit Rights), 12 (Data Return & Deletion), 13 (Liability), and 15 (Governing Law).
15. Governing Law
This DPA shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein. Any dispute arising under this DPA shall be subject to the dispute resolution procedures set forth in the Terms of Service, including binding arbitration administered by the ADR Institute of Canada.
16. Contact
For questions about this DPA or to exercise rights under it:
Privacy Officer: R Gupta Consultancy Services Inc.
Email: [email protected]
Support: [email protected]
Website: gridowl.ca
March 17, 2026 | © R Gupta Consultancy Services Inc. (RGCS)