Data Processing Agreement

As of March, 2026

This Data Processing Agreement (“DPA”) applies where Toth-Leanboost processes personal data on behalf of a Client.

1. Roles

The Client acts as data controller.

Toth-Leanboost acts as data processor and processes personal data solely on behalf of the Client.

2. Purpose and Scope

Processing is carried out only to:

  • deliver consulting, coaching, workshops, and assessment services

  • enable collaboration and analysis

3. Categories of Data

Personal data may include:

  • identification and contact data

  • professional and organizational data

  • survey responses and feedback

  • assessment-related insights

4. Duration

Processing continues:

  • for the duration of the service engagement

  • until deletion or return is requested

  • subject to legal retention obligations

5. Instructions

Toth-Leanboost processes data only on documented instructions from the Client unless required by law.

6. Confidentiality

All persons authorized to process personal data are bound by confidentiality obligations.

7. Security Measures

Toth-Leanboost implements appropriate technical and organizational measures including:

  • role-based access controls

  • secure hosting environments

  • restricted administrative access

8. Sub-processors

Approved sub-processors include hosting, payment, storage, and communication providers.

Toth-Leanboost remains responsible for sub-processor compliance.

Clients may object to new sub-processors on reasonable grounds.

9. Assistance

Toth-Leanboost shall reasonably assist the Client in responding to:

  • data subject requests

  • supervisory authority inquiries

  • security incidents

10. Breach Notification

Toth-Leanboost shall notify the Client without undue delay after becoming aware of a personal data breach.

11. Return or Deletion

Upon termination, personal data shall be:

  • returned

  • deleted

  • or anonymized

unless retention is required by law.

12. Liability

Liability for data protection obligations follows the main agreement and applicable law.