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Data Processing Addendum

Effective date: June 26, 2026

This Data Processing Addendum (“DPA”) forms part of, and is incorporated by reference into, the Terms of Service (the “Agreement”) between Anderson Solutions Group LLC (d/b/a RentalPilot) (“RentalPilot,” “Processor,” “we,” or “us”) and the operator that subscribes to the Service (“Operator,” “Controller,” or “you”). It governs our processing of personal data relating to your renters and other individuals whose data you process through the Service (“Renter Personal Data”). Where there is a conflict between this DPA and the rest of the Agreement on the subject of data protection, this DPA controls.

This DPA applies to the extent RentalPilot processes Renter Personal Data on your behalf and to which data protection laws apply, including the EU and UK General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act as amended (“CCPA/CPRA”).

1. Definitions

Capitalized terms not defined here have the meaning given in the Agreement or in applicable data protection law. “Controller,” “Processor,” “Data Subject,” “Personal Data,” “Processing,” and “Personal Data Breach” have the meaning given in the GDPR. “Sub-processor” means any third party engaged by RentalPilot to process Renter Personal Data. “Data Protection Laws” means all laws relating to data protection and privacy applicable to the processing under this DPA. “Standard Contractual Clauses” (“SCCs”) means the clauses approved by the European Commission for transfers of personal data to third countries.

2. Roles of the parties

  • Renter Personal Data — you are the Controller and RentalPilot is the Processor. You determine the purposes and means of processing Renter Personal Data; we process it only to provide the Service and on your documented instructions.
  • Operator account and platform data — RentalPilot is the Controller. Our processing of operator account data and platform analytics is governed by our Privacy Policy, not this DPA.

3. Scope and details of processing

The subject matter, duration, nature and purpose of the processing, the types of Personal Data, and the categories of Data Subjects are described in Annex I. We will process Renter Personal Data only for the duration of the Agreement and as needed to provide the Service, except where retention is required by law (see Section 4.8).

4. RentalPilot’s obligations as Processor

4.1 Processing on documented instructions

We process Renter Personal Data only on your documented instructions, including with regard to international transfers, unless required to do otherwise by law (in which case we will inform you, unless legally prohibited). The Agreement, this DPA, and your use of the Service’s features constitute your complete and final instructions. We will inform you if, in our opinion, an instruction infringes Data Protection Laws.

4.2 Confidentiality

We ensure that personnel authorized to process Renter Personal Data are bound by appropriate obligations of confidentiality and process the data only as necessary to provide the Service.

4.3 Security

We implement and maintain appropriate technical and organizational measures designed to protect Renter Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, taking into account the state of the art, the costs of implementation, and the nature, scope, and purposes of processing. A description of these measures is set out in Annex II.

4.4 Sub-processors

You provide general authorization for RentalPilot to engage Sub-processors to process Renter Personal Data. Our current Sub-processors are listed in Annex III. We impose data protection obligations on each Sub-processor that are no less protective than those in this DPA, and we remain responsible for each Sub-processor’s performance. We will give you advance notice of any intended addition or replacement of a Sub-processor (see Annex III), and you may object on reasonable data protection grounds as described there.

4.5 Assistance with data subject rights

Taking into account the nature of the processing, we assist you by appropriate technical and organizational measures, insofar as possible, to respond to requests from Data Subjects exercising their rights (such as access, correction, deletion, and portability). The Service includes self-service tools that let you export and erase a renter’s personal data directly. If a Data Subject contacts us directly about Renter Personal Data, we will refer them to you and assist you in responding.

4.6 Assistance with security, breaches, and impact assessments

Taking into account the nature of processing and the information available to us, we assist you in ensuring compliance with your obligations regarding security of processing, notification of Personal Data Breaches, data protection impact assessments, and prior consultation with supervisory authorities (Articles 32–36 GDPR).

4.7 Personal data breach notification

We notify you without undue delay after becoming aware of a Personal Data Breach affecting Renter Personal Data, and provide information reasonably available to us to help you meet your own notification obligations.

4.8 Return or deletion

On termination of the Agreement, and at your choice, we delete or return Renter Personal Data and delete existing copies, unless retention is required by law. The Service also applies an automatic retention period to certain renter media (for example, driver’s-license images and vehicle photos), after which those files are deleted while transactional and financial records are retained for legal and accounting purposes (see Annex II).

4.9 Records and audits

We make available to you information reasonably necessary to demonstrate compliance with this DPA and allow for and contribute to audits, including inspections, conducted by you or an auditor you mandate, subject to reasonable notice, confidentiality, and frequency limits, and conducted so as not to compromise the security or confidentiality of other customers’ data. We may satisfy audit requests by providing relevant third-party certifications or reports where available.

5. Your obligations as Controller

You represent and warrant that you have a lawful basis to collect and process Renter Personal Data and to provide it to us for processing, that you have provided all required notices and obtained all required consents from Data Subjects, and that your instructions comply with Data Protection Laws. You are responsible for the accuracy, quality, and legality of Renter Personal Data and the means by which you acquired it.

6. International data transfers

Our hosting and several Sub-processors are located in the United States. Where this DPA involves a transfer of Renter Personal Data from the European Economic Area, the United Kingdom, or Switzerland to a country that has not received an adequacy decision, the parties agree that the applicable Standard Contractual Clauses (and the UK International Data Transfer Addendum, where relevant) are incorporated into this DPA by reference and apply to that transfer, with RentalPilot acting as “data importer” and the Operator as “data exporter.”

7. Liability

Each party’s liability arising out of or related to this DPA is subject to the limitations and exclusions of liability set out in the Agreement.

8. Term, precedence, and governing law

This DPA takes effect on the effective date above and remains in effect for as long as we process Renter Personal Data on your behalf. This DPA is governed by the law of the State of Wyoming, except where Data Protection Laws require otherwise. If any provision of this DPA conflicts with the Agreement on the subject of data protection, this DPA prevails.

9. Contact

Questions about this DPA, or requests to exercise audit or assistance rights, may be directed to:

  • Anderson Solutions Group LLC (d/b/a RentalPilot)
  • 1309 Coffeen Avenue, Suite 1200, Sheridan, WY 82801
  • info@rentalpilot.io

Annex I — Description of the processing

  • Parties. Data exporter / Controller: the Operator subscribing to the Service. Data importer / Processor: Anderson Solutions Group LLC (d/b/a RentalPilot) (RentalPilot).
  • Subject matter. Provision of the RentalPilot car-rental management platform and the hosted public booking site to the Operator.
  • Duration. The term of the Agreement, plus any period required for return or deletion of data and any legally required retention.
  • Nature and purpose. Hosting, storing, organizing, retrieving, transmitting, and otherwise processing Renter Personal Data to enable the Operator to manage bookings, vehicles, customers, payments, documents, and communications, and — where the Operator enables them — optional AI-assisted features (license verification, damage detection, and a support assistant).
  • Types of Personal Data. Renter name, email, phone, date of birth, driver’s-license number and images, signatures, vehicle-condition photos, proof-of-insurance documents (where an operator requires them at booking), booking and payment-reference details, and communications. Full payment card numbers are not processed or stored by RentalPilot (handled by Stripe).
  • Categories of Data Subjects. The Operator’s renters and prospective renters, and other individuals whose data the Operator submits through the Service.
  • Sensitive data. Driver’s-license images may be processed; the Service is designed to minimize sensitive data (for example, license numbers are not extracted or stored by the optional AI license-read feature).

Annex II — Technical and organizational measures

RentalPilot maintains measures including, as applicable:

  • Encryption in transit — HTTPS/TLS for data moving between devices and our services.
  • Encryption at rest — stored files, including driver’s-license images, signatures, and vehicle photos, are encrypted at rest in object storage.
  • Access controls and tenant isolation — access to Personal Data is limited to authorized personnel and systems, with role-based access and logical separation so one operator cannot access another operator’s data.
  • Private, authentication-gated storage — sensitive files are not publicly accessible and are served only through authenticated, tenant-scoped requests.
  • Credential protection — account passwords are stored hashed; cardholder data is handled within Stripe’s PCI-DSS-certified environment.
  • Data minimization and retention — the optional AI license-read feature does not store license numbers; renter media is automatically deleted after a defined retention period while financial and transactional records are retained as required.
  • Monitoring and resilience — error and performance monitoring, and regular database backups, to support availability and recovery.

Annex III — Sub-processors

RentalPilot engages the following Sub-processors to process Renter Personal Data. Hosting is primarily in the United States.

  • Stripe — payment processing for renter transactions.
  • Render — application and database hosting (United States).
  • Vercel — front-end and content-delivery-network hosting.
  • Cloudflare R2 — file and object storage (license images, signatures, vehicle photos, proof-of-insurance documents).
  • PostHog — product analytics and session replay on the public booking flow (form inputs masked, payment fields excluded).
  • Sentry — error and performance monitoring (configured not to send personal data by default).
  • Resend — transactional email delivery.
  • Anthropic — AI provider for the optional, operator-enabled AI features; processes license and vehicle images only when those features are enabled, and does not use the data to train its models.

Change notification. We maintain the current list of Sub-processors on this page. Before adding or replacing a Sub-processor that processes Renter Personal Data, we will update this list and provide reasonable advance notice (for example, by email to the operator’s account contact or an in-product or website notice). If you object on reasonable data protection grounds within the notice period, we will work with you in good faith to address the concern; if we cannot, you may terminate the affected part of the Service as your exclusive remedy.