Legal · Processor addendum
Processor Addendum.
The Processor Addendum to the Master License Agreement, between Riley Ventures LLC ("data.cool"), acting for each owner whose Dataset is licensed, and the buyer organization that signs it ("Buyer"). It applies only to licenses taken with the light scrub. Version 2026-10-30.1.
Coming soon. The light scrub isn't offered yet; this addendum applies once it is.
Effective October 7, 2026 · Last updated October 30, 2026
1. What the light scrub leaves in
Ordinary business contact details in the licensed data (names, work emails and phone numbers of employees, customers and suppliers in their business roles) are delivered as they are, rather than replaced with consistent pseudonyms. Everything else the full scrub removes is still removed: secrets and credentials, payment data, health and other sensitive categories, the owner's never-share list and the seller's identity.
2. Buyer as processor
- Buyer processes that personal data on the owner's documented instructions, which are the license's permitted use, and for no other purpose. The Data Processing Addendum applies to it as if Buyer were data.cool's subprocessor.
- Buyer will not contact, profile or re-identify any person in the data, or combine it with other data to do so, and will not use it to make decisions about any person.
- Buyer keeps it under access control and encryption, limits it to staff and contractors who need it and are bound to confidentiality, and keeps a record of who has had access.
- On a request from data.cool (for an owner, or for a person exercising their rights), Buyer deletes or corrects the records named within 30 days and confirms in writing. That includes copies held by downstream recipients.
- Buyer notifies privacy@data.cool within 72 hours of becoming aware of a personal data breach, and cooperates in the response.
3. Transfers and onward recipients
Buyer passes light-scrub data to a downstream recipient only if that recipient is on Buyer's list and has signed terms at least as protective as this addendum. Transfers out of the country where the data was handed over follow the transfer terms of the DPA.
4. Records and audit
On reasonable notice, and no more than once a year unless there is a breach, Buyer answers data.cool's written questions about its handling of light-scrub data and makes its access records available.
Riley Ventures LLC, a Florida limited liability company, 1615 S Congress Ave, Ste 103, Delray Beach, FL 33445. Questions: legal@data.cool. All legal documents: /legal.