Data Processing Disclosure

Effective Date: April 13, 2025

This Data Processing Disclosure outlines how Real IQ LLC ("we", "our", or "us") processes data on behalf of our users and clients through the RealIQData.com platform, in compliance with applicable privacy laws including GDPR, CCPA, and other data protection regulations.

1. Role as Data Processor

In most cases, we act as a data processor when handling personal data on behalf of our users. This means we process data solely under the instruction of the data controller (our client), and not for our own purposes.

2. Types of Data Processed

We may process the following types of personal data:

Contact information (e.g., name, phone number, email)
Customer records and communications
Marketing engagement data (emails, SMS logs, form submissions)
IP addresses and device/browser data (used for security and performance)

3. Lawful Basis for Processing

We process data based on the controller’s lawful basis, which may include consent, contractual necessity, or legitimate interest. Controllers are responsible for ensuring they have proper legal grounds for collecting and submitting personal data to our platform.

4. Sub-Processors

We use trusted sub-processors (e.g., GoHighLevel, Twilio, Stripe) to provide infrastructure, communication, and payment services. All sub-processors are contractually bound to protect personal data to the same level required by law.

5. Data Transfers

Personal data may be stored and processed in the United States or other countries where our sub-processors operate. We ensure appropriate safeguards are in place for international data transfers, such as Standard Contractual Clauses (SCCs).

6. Data Subject Rights

We support the data controller’s obligation to comply with data subject rights requests (e.g., access, correction, deletion). Requests submitted to us will be forwarded to the appropriate controller for action.

7. Security and Confidentiality

We maintain technical and organizational security measures to protect data from unauthorized access, loss, or disclosure. All data is encrypted in transit and at rest where applicable.

8. Retention and Deletion

We retain personal data only for as long as needed to provide services or as required by law. Upon cancellation or written request, we delete data in accordance with applicable retention policies.