GridOwl Platform

v1.0 — March 17, 2026

Data Processing Agreement

GridOwl Platform — PIPEDA-Compliant Data Processing Terms

About this DPA: This Data Processing Agreement (“DPA”) forms part of the Terms of Service between R Gupta Consultancy Services Inc. (“RGCS”, “Processor”) and the organization subscribing to GridOwl (“Customer”, “Controller”). It governs the processing of personal data by RGCS on behalf of the Customer.

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:

a.Ensure that all Personal Data provided to RGCS has been collected in compliance with PIPEDA and any applicable provincial privacy legislation, including obtaining meaningful consent from data subjects where required.
b.Provide lawful processing instructions to RGCS that are consistent with applicable law.
c.Promptly notify RGCS of any changes in applicable privacy laws that may affect RGCS’s processing obligations.
d.Be solely responsible for determining the lawful basis for processing and for providing any required notices to data subjects.

5. Processor Obligations

RGCS, as Processor, shall:

a.Process Personal Data only on documented instructions from the Customer, unless required to do so by Canadian federal or provincial law. If such a legal requirement exists, RGCS shall inform the Customer before processing (unless legally prohibited from doing so).
b.Ensure that all persons authorized to process Personal Data have committed themselves to confidentiality obligations or are under an appropriate statutory obligation of confidentiality.
c.Implement and maintain the technical and organizational security measures described in Section 6 of this DPA.
d.Not use Personal Data for any purpose other than providing the Service, and never for RGCS’s own marketing or analytics purposes.
e.Assist the Customer in fulfilling its obligations to respond to data subject access requests and exercise of data subject rights under PIPEDA.

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:

a.Provide the Customer with at least thirty (30) days’ prior written notice (via the email address on the Customer’s account) before adding or replacing any Sub-Processor.
b.Allow the Customer fourteen (14) calendar days from the date of notification to object in writing to the proposed Sub-Processor change.
c.If the Customer raises a reasonable objection, RGCS shall work in good faith to offer an alternative solution. If no resolution is reached, the Customer may terminate the affected Service without penalty, subject to the data export period in Section 12.
d.Impose data protection obligations on each Sub-Processor that are no less protective than those in this DPA, by way of a written contract.

Current Sub-Processors

Sub-ProcessorPurposeLocation
Amazon Web Services (AWS)Cloud infrastructure & hostingCanada / US
The Things Industries (TTI)LoRaWAN network serverUS (nam1 cluster)
CloudflareDNS, SSL, DDoS protectionGlobal (edge network)
PostHogProduct 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:

a.Promptly notify the Customer within five (5) business days of receiving the request.
b.Not respond directly to the data subject unless authorized by the Customer or required by law.
c.Provide the Customer with reasonable technical assistance to fulfill the request, including providing data exports in CSV or PDF format through the platform’s built-in export tools.

9. Data Breach Notification

In the event of a Data Breach, RGCS shall:

a.Notify the Customer without undue delay, and in any event within seventy-two (72) hours of becoming aware of the breach, via the Tenant Admin email address and any emergency contact on file.
b.Provide the Customer with sufficient information to meet its own breach reporting obligations to the Office of the Privacy Commissioner of Canada (OPC) and affected individuals, including: the nature of the breach, categories and approximate number of data subjects affected, likely consequences, and measures taken or proposed to address the breach.
c.Take immediate steps to contain and remediate the breach, and cooperate with the Customer in investigating and mitigating its effects.
d.Maintain records of all Data Breaches for a minimum of two (2) years, including facts relating to the breach, its effects, and remedial actions taken, as required by PIPEDA.

10. International Data Transfers

Personal Data is primarily processed in Canada and the United States. Where Personal Data is transferred outside of Canada:

a.RGCS shall ensure that the transfer is conducted in compliance with PIPEDA’s accountability principle (Principle 1), meaning RGCS remains responsible for Personal Data in its possession or custody, including data transferred to Sub-Processors.
b.RGCS shall use contractual means to ensure that any Sub-Processor in a foreign jurisdiction provides a comparable level of protection to that required under Canadian privacy law.
c.Upon request, RGCS shall inform the Customer of the specific countries where Personal Data may be processed and the safeguards in place.

11. Audit Rights

RGCS shall make available to the Customer all information reasonably necessary to demonstrate compliance with this DPA:

a.The Customer may conduct audits (or appoint a qualified third-party auditor bound by confidentiality) no more than once per calendar year, with at least thirty (30) days’ prior written notice.
b.Audits shall be conducted during normal business hours, at the Customer’s expense, and shall not unreasonably disrupt RGCS’s operations.
c.RGCS shall cooperate in good faith and provide access to relevant documentation, systems (in read-only mode), and personnel as reasonably required.
d.If an audit reveals material non-compliance, RGCS shall remediate the identified issues at its own expense within a commercially reasonable timeframe.

12. Data Return & Deletion

Upon termination or expiry of the Customer’s subscription:

a.RGCS shall provide a thirty (30) calendar day read-only export window during which the Customer may download all Personal Data in CSV and/or PDF format via the platform’s export functionality.
b.Following the export window, RGCS shall delete all Personal Data within thirty (30) calendar days, unless retention is required by law (e.g., HACCP audit logs retained for a minimum of 2 years as required by food safety regulations).
c.Where legally mandated retention applies, affected data shall be anonymized (personal identifiers removed) and access shall be restricted to authorized compliance personnel only.
d.Upon request, RGCS shall provide written certification of deletion to the Customer.

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:

a.RGCS’s aggregate liability arising out of or related to this DPA shall not exceed the total fees paid by the Customer to RGCS in the twelve (12) months preceding the event giving rise to the claim.
b.Neither party excludes or limits liability for losses that cannot be lawfully excluded or limited under applicable law, including fraud or willful misconduct.

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)

GridOwl Platform

Ready to monitor your cold chain?

Free 30-day pilot for Ottawa–Gatineau restaurants. No contract, no WiFi needed.