# RILLA Shield — Data Processing Addendum (DPA)

**Status:** Template, available on request. Contact security@rillashield.app for a counter-signable version.

This DPA forms part of the agreement between the Customer and RILLA Shield Pty Ltd ("RILLA") and governs the processing of Personal Data by RILLA on behalf of the Customer.

## 1. Roles
Customer is the Data Controller. RILLA is the Data Processor.

## 2. Subject matter and duration
Processing is performed for the duration of the Customer's subscription and for the limited retention periods set out in RILLA's Privacy Policy.

## 3. Nature and purpose of processing
Detection and prevention of invoice fraud, payee verification, supplier risk scoring, and the production of evidence packs in the event of a suspected incident.

## 4. Categories of data subjects
Customer's employees, suppliers, and counterparties referenced in invoices and payment instructions submitted to the Service.

## 5. Categories of Personal Data
Business contact details, banking identifiers (BSB / account number / IBAN), ABN/ACN, email metadata, invoice contents.

## 6. Sub-processors
See `/compliance/sub-processors.md`. Customer is notified of material changes with 30 days' notice.

## 7. Security measures
See `/security`. Encryption in transit (TLS 1.2+) and at rest (AES-256), Row Level Security on all customer data, immutable audit log, MFA available to all users, Australian-region hosting.

## 8. Data subject rights
RILLA assists the Customer in responding to data subject requests within statutory timeframes.

## 9. Personal Data breach
RILLA notifies the Customer without undue delay and within 72 hours of becoming aware of a Personal Data breach affecting Customer data.

## 10. Return and deletion
On termination, Customer data is deleted within 30 days unless retention is required by law.

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_This document is a template made available for procurement review. The counter-signable version is issued under NDA._
