Data Processing Addendum

How Toshi Consulting Services processes the personal data you control, as your processor.

Version 2026-10-23

Draft for review. This is a plain-language draft and not legal advice; it is being reviewed by our legal adviser.

Roles

For the CRM content you put in, you are the data fiduciary and we are your data processor. This addendum forms part of the Terms of Service.

Our obligations

We process your customer data only on your instructions and to provide the service.

We keep it confidential, secure it with appropriate measures, and help you meet requests from the people whose data it is (access, correction, erasure).

We use sub-processors (hosting, payments, email, messaging, AI) bound to similar obligations, and remain responsible for them.

Breach and deletion

We will tell you without undue delay about a personal-data breach affecting your data, and help you respond.

On account closure we delete or return your data after the grace period, unless the law requires otherwise.

Your obligations

You must have a lawful basis to process the personal data you put in, give required notices to the people it is about, and only send us data you are allowed to.