Data Processing Addendum (DPA)

This Data Processing Addendum ("DPA") forms part of the agreement between the institution ("Controller") and Choice Pursuits Technologies LLC ("Processor") for the VerbalCheck platform.

Roles

The Institution is the Data Controller. Choice Pursuits is the Data Processor.

Processing Purposes

Processing supports academic integrity verification, assignment workflows, scoring, and reporting as directed by the Institution.

Categories of Data

• Student identifiers and enrollment context
• Assignment submissions and interview responses
• System usage metadata and logs

Confidentiality

Processor ensures personnel with access to personal data are bound by confidentiality obligations.

Security Safeguards

Processor implements appropriate technical and organizational measures, including access controls, encryption in transit, and audit logging.

Subprocessor Approval

Processor will notify Controller of material subprocessor changes and provide a reasonable opportunity to object.

Audit Rights (Paper Only)

Controller may request written responses to security questionnaires or certifications. On-site audits are not required unless mutually agreed.

Breach Notification

Processor will notify Controller without undue delay and within 72 hours of confirming a reportable security incident.

Data Return or Deletion

Upon termination, Processor will return or delete personal data as instructed by the Controller, subject to legal obligations.

Survival

Confidentiality, security, and data handling obligations survive termination of the services agreement.