Data Processing Agreement

How we process your leads' data on your behalf.

Last updated: September 16, 2026 • Version 1.0 — template

This is a template, not a signed contract. There is no single official "ICO DPA template" — the ICO publishes guidance on what UK GDPR Article 28 requires a processor agreement to contain, and this document is drafted against that guidance for Racso's actual data flows (described in our Privacy Policy). It has not been reviewed by a solicitor. Before relying on this as a binding contract — for either party — please have it reviewed by your own legal advisor. To get a countersigned copy, email hello@racsosolutions.co.uk.

1. Parties

This Data Processing Agreement ("DPA") is between:

This DPA forms part of, and is incorporated into, our Terms & Conditions. If there's a conflict between this DPA and the Terms on data protection matters, this DPA takes priority.

2. Subject matter and duration

Racso processes personal data on your behalf for as long as your Racso account is active, plus the post-closure retention period set out in our Privacy Policy (currently 30 days, to allow export, then deletion).

3. Nature and purpose of processing

Racso processes personal data to: receive and respond to SMS messages from your leads; qualify leads via an automated conversation; check and reserve test-drive appointment slots; send same-day SMS reminders; look up a vehicle registration against the DVLA's public vehicle data, where you use that feature; and display all of the above to your staff in the Racso dashboard.

4. Types of personal data processed

Racso does not intentionally collect special category data (e.g. health, religion, ethnicity) about leads, and asks you not to configure custom qualifying questions that would solicit it.

5. Categories of data subjects

6. Racso's obligations as processor (UK GDPR Article 28)

Racso agrees to:

7. Authorised sub-processors

You authorise Racso to engage the following sub-processors, each processing only what's needed for its specific function:

Sub-processorFunctionLocation
TwilioSMS sending and receivingUSA (SCC-covered)
RailwayApplication and database hostingUSA (SCC-covered)
Google (Gmail)Sending booking-confirmation and digest emailsUSA (SCC-covered)
DVLA Vehicle Enquiry ServiceVehicle registration lookups (no personal data sent — see §4)UK

We'll give you at least 30 days' notice before adding or replacing a sub-processor that processes your leads' personal data, so you have the chance to object on reasonable data-protection grounds.

8. International transfers

Where a sub-processor above is located outside the UK/EU, Racso relies on Standard Contractual Clauses (SCCs) or an equivalent recognised transfer mechanism with that sub-processor.

9. Liability

Liability under this DPA follows the limitation of liability set out in our Terms & Conditions §9, except to the extent that liability cannot lawfully be limited (for example, liability arising from Racso's own breach of UK GDPR as a processor).

10. Term and termination

This DPA remains in effect for as long as Racso processes personal data on your behalf under your Racso account, and terminates automatically when that processing ends (see §2).

11. Governing law

This DPA is governed by English law, consistent with our Terms & Conditions.

12. Requesting a countersigned copy

Email hello@racsosolutions.co.uk with your business name and account email to request a version of this DPA signed by both parties.

See also: Privacy Policy · Terms & Conditions · Refund Policy · Cookie Policy

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