Version 1.0 · Effective 2026-08-29 · sha256 ae544b2e0dabee34ce56b265046674d07e86c25eb774280b4911ce7a42e4e19b
California Beta - Version 1.0
August 29, 2026
This California Data Processing Addendum ("DPA") forms part of the BLUNA Platform Terms of Service ("Platform Terms") between BLUNA LLC, a California limited liability company, operating the BLUNA beta platform ("BLUNA"), and the Property Customer identified in the applicable BLUNA account or Quote ("Customer") when the applicability conditions in Section 1 are met.
1.1 This DPA applies only to California personal information that Customer discloses or makes available to BLUNA for processing on Customer's behalf in connection with an authorized Job or Customer account, where Customer is a "business" and BLUNA is a "service provider" or "contractor" as those terms are defined by the California Consumer Privacy Act and its implementing regulations (collectively, "CCPA").
1.2 The parties acknowledge that role depends on the processing purpose. This DPA does not convert into Customer-controlled processing personal information that BLUNA processes independently for its own account administration, billing and commission records, fraud prevention, security, legal compliance, enforcement, or other independent Platform purposes disclosed in the BLUNA Privacy Policy.
1.3 If the CCPA does not apply to Customer or the relevant processing, the Platform Terms and Privacy Policy continue to govern, and this DPA does not create CCPA rights or obligations that otherwise would not apply except for contractual duties expressly stated without statutory qualification.
Customer instructs BLUNA to process Covered Personal Information only as reasonably necessary to provide and improve the services specified in the Platform Terms and accepted Quotes, including request intake; Job scoping, assignment and coordination; use of property address/unit information; controlled unit access; before-and-after photography; maintenance and service-history records; authorized future service/estimating; communications; support; quality/rework/dispute handling; payment administration; security; fraud prevention; and compliance with applicable law. BLUNA will not process Covered Personal Information for a purpose materially outside these instructions unless required by law or Customer gives a lawful additional instruction in writing.
For clarity, "Covered Personal Information" means personal information subject to this DPA and does not include information that is lawfully deidentified or aggregated so that it is not personal information under applicable law, provided the applicable legal requirements for that treatment are maintained.
With respect to Covered Personal Information, BLUNA will:
BLUNA will limit access to Covered Personal Information to personnel and authorized providers that need access for the permitted purposes and that are subject to confidentiality obligations or professional duties appropriate to the information. BLUNA will maintain reasonable access controls and review access where operationally appropriate.
BLUNA will implement and maintain reasonable administrative, technical, and physical safeguards appropriate to the nature of Covered Personal Information and the risks presented by the processing. For the beta, safeguards should include authenticated access, least privilege, encryption in transit and at rest, logging, secure cloud configurations, vulnerability and dependency maintenance, and an incident-response process. Restricted Access Data, including lockbox codes and unit-access instructions, receives additional controls: designated restricted fields; access limited to the assigned on-site technician and limited personnel with a current Job need; short, watermarked display windows where implemented; no credential values in ordinary messages, analytics, general exports, or AI prompts; access-event logging without logging the credential value; automatic visibility expiry; and deletion of the credential value as soon as operationally practicable and in all events within 24 hours after the Job access need ends, subject only to a specific incident or legal-preservation need.
Customer remains responsible for secure account administration, limiting its own users, providing lawful and accurate access instructions, using temporary or one-time access codes where reasonably available, rotating or revoking credentials after the Job or suspected compromise, avoiding unnecessary resident information in Job submissions, and having lawful authority to capture and provide Job Photos and property/access data to BLUNA for the authorized Job.
Customer authorizes BLUNA to use subprocessors reasonably necessary to operate the Platform, including cloud hosting, database, communications, SMS, support, security, analytics, AI-assistance, and payment-related providers. BLUNA will require each subprocessor that processes Covered Personal Information to be bound by written obligations that provide the same level of privacy protection required by the CCPA for the relevant processing and are no less protective in material respects than the obligations BLUNA must pass through under this DPA.
BLUNA will maintain a current internal list of material subprocessors for the beta and will provide it to Customer on reasonable request. If BLUNA later establishes a public subprocessor page, that page may satisfy this information obligation.
If BLUNA receives a request from a California consumer relating solely to Covered Personal Information processed on Customer's behalf, BLUNA may direct the consumer to Customer unless prohibited by law. BLUNA will provide commercially reasonable assistance needed for Customer to respond, including search, access, correction, deletion, or export support to the extent applicable and technically feasible. Customer is responsible for determining the legal response to a request concerning Customer-controlled processing.
At Customer's written request or termination of the relevant service, BLUNA will delete or return Covered Personal Information within a commercially reasonable period, except to the extent retention is required or permitted by law, reasonably necessary for security, fraud prevention, accounting, payment reconciliation, legal claims, or another purpose for which BLUNA independently processes the information under applicable law. Any retained copy remains protected under applicable confidentiality, security, and use restrictions for as long as it remains Covered Personal Information. The beta schedule in the Privacy Policy applies unless Customer has a lawful, technically feasible shorter instruction that controls the processing.
Restricted Access Data values are removed from routine operational access when the Job access need ends and are scheduled for deletion as soon as operationally practicable and in all events within 24 hours after Job closeout, cancellation, or reassignment. Non-secret access audit events may be retained for three years. Original unredacted Job Photos are scheduled for deletion 30 days after Job closeout unless a documented dispute, rework, security incident, chargeback, insurance claim, or legal hold requires temporary preservation through resolution plus 90 days. The long-term retained copy should be blurred/redacted where technically feasible. Customer may request shorter deletion of ordinary Job Photos or resident data when no longer needed for the authorized Job, subject to applicable exceptions.
BLUNA may maintain address/unit-linked property service history for the period stated in the Privacy Policy where reasonably necessary for Customer service and authorized Platform operations. Cross-customer analytics, benchmarking, or model use must use deidentified or aggregated data that excludes Restricted Access Data, resident names/contact details, identifiable resident imagery, and address/unit identifiers or other data reasonably capable of linking the record to a consumer or household. BLUNA will not reidentify data treated as deidentified.
On reasonable written request, BLUNA will make available information reasonably necessary to demonstrate compliance with this DPA and applicable CCPA service-provider or contractor requirements. Customer may take reasonable and appropriate steps to verify compliance, including a questionnaire or review of relevant policies or third-party assurance material if available. Any direct audit must be reasonably scoped, protect other customers' confidentiality and system security, avoid unreasonable disruption, and occur no more than annually unless a material incident or regulator requirement reasonably justifies additional review.
BLUNA will notify Customer without unreasonable delay after confirming unauthorized access to or acquisition of Covered Personal Information that materially affects Customer and requires Customer action under applicable law or contract. Notice will include information reasonably available to BLUNA about the nature of the incident, affected data, mitigation, and relevant response steps. Notice is not an admission of fault or liability. Customer and BLUNA will reasonably coordinate legally required notices concerning the affected Covered Personal Information.
BLUNA will not use identifiable resident Covered Personal Information or identifiable Job Photos to train a general-purpose AI model. AI-assisted processing for Customer's authorized Job may be used for routing, summarization, classification, drafting, quality review, fraud or security, or similar Platform support where the processing remains within the permitted purposes and applicable service-provider or contractor restrictions. Customer will not instruct BLUNA to use Covered Personal Information for resident screening, rent setting, eviction decisions, or other unrelated resident profiling through the beta.
| Item | Description |
|---|---|
| Subject matter | Operation of a California property-service coordination platform and administration of Customer Jobs. |
| Duration | For the Customer relationship, active Jobs, and permitted retention period. |
| Nature and purpose | Collection, hosting, organization, transmission, restricted unit-access display, authorized future service history, display to authorized Job participants, support, coordination, documentation, security, payment administration, rework/dispute handling, blurring/redaction, deletion, deidentification, and authorized AI-assisted support. |
| Data subjects | Customer personnel; residents/occupants incidentally represented in authorized Job data; Vendor personnel where Customer submits their information. |
| Categories | Identifiers/contact data; property address and unit number; Restricted Access Data including lockbox or gate codes and access instructions; before-and-after Job Photos; paint colors; bulb counts/types; appliance type/manufacturer/model; flooring; condition/repair/maintenance history; service requests; notes; communications; transaction references; security logs; and other personal information Customer lawfully submits for an authorized Job. |
| Sensitive data expected | Restricted Access Data and, in limited circumstances, other sensitive or private information incidentally submitted. BLUNA treats unit-access credentials as high-risk security information whether or not a specific field falls within the CCPA statutory definition of sensitive personal information. Customer is instructed not to submit resident financial, medical, screening, government-ID, or similar unnecessary sensitive data. |
| Frequency | As needed for Customer account operation and individual Jobs. |
| Subprocessors | Cloud, database, communications/SMS, support, security, analytics/AI-assistance, and payment-related service providers under written restrictions appropriate to role. |
If this DPA conflicts with the Platform Terms regarding Covered Personal Information, this DPA controls to the extent of the conflict. BLUNA may update this DPA to reflect a change in applicable law or materially improved privacy terms, but a change that materially reduces Customer's data-protection rights will require notice and, where legally appropriate, renewed acceptance. Sections concerning use restrictions, confidentiality, security, deletion/retention, and compliance survive for as long as BLUNA retains Covered Personal Information.