Last updated: August 28, 2025
Effective May, 2025
(A) Controller and Processor entered into Gro’s Terms & Conditions (Master Agreement), which govern Controller’s use of the Gro platform provided by Processor;
(B) Due to the scope and subject matter of the Master Agreement, it is necessary for the Processor to process Personal Data on behalf of Controller.
(C) This Personal Data Processing Agreement (Agreement) sets out the additional terms, requirements and conditions on which Processor will process Personal Data under the Master Agreement. This Agreement is an integral part of the Master Agreement and contains the mandatory clauses required by the Personal Data Protection Act 2012 (No. 26 of 2012) for contracts between data controllers and data processors.
The following definitions and rules of interpretation apply in this Agreement.
2.1 Controller and Processor acknowledge that as per definitions in the Data Protection Legislation. Controller is the Controller and Processor is the Processor.
2.2 Controller retains control of the Personal Data and remains responsible for its compliance obligations under the applicable Data Protection Legislation, including providing any required notices and obtaining any required consents, and for the processing instructions it gives to Processor.
2.3 ANNEX A describes the subject matter, duration, nature and purpose of processing, Personal Data categories, Data Subject categories in respect of which Processor may process Personal Data, as well as the relevant security measures to be taken by Processor.
2.4 ANNEX B provides the list of subprocessors involved by Processor.
3.1 Processor will only process the Personal Data in accordance with Controller's written instructions specified in Annex A. Processor will not process the Personal Data for any other purpose or in a way that does not comply with this Agreement or Data Protection Legislation. Processor must promptly notify Controller if, in its opinion, Controller's instruction would not comply with Data Protection Legislation.
3.2 Processor must promptly comply with any of Controller’s requests or instruction from Authorised Persons requiring Processor to amend, transfer, delete or otherwise process the Personal Data, or to stop, mitigate or remedy any unauthorised processing.
3.3 Processor will maintain the confidentiality of all Personal Data and will not disclose Personal Data to third parties unless Controller or this Agreement specifically authorises the disclosure, or as required by law. If a law, court, regulator or supervisory authority requires Processor to process or disclose Personal Data, Processor must first inform Controller of the legal or regulatory requirement and give Controller an opportunity to object or challenge the requirement, unless the law prohibits such notice.
3.4 Processor will reasonably assist Controller with meeting Controller's compliance obligations under Data Protection Legislation, taking into account the nature of Processor's processing and the information available to Processor, including in relation to Data Subject rights, data protection impact assessments and reporting to and consulting with supervisory authorities under the Data Protection Legislation.
3.5 Processor must promptly notify Controller of any changes to Data Protection Legislation that may adversely affect Processor's performance of the Master Agreement.
3.6 Processor’s employees
3.7 Processor will ensure that all employees:
3.8 Processor will take reasonable steps to ensure the reliability, integrity and trustworthiness of and conduct background checks consistent with applicable law on all of Processor's employees with access to the Personal Data.
4.1 Processor must at all times implement appropriate technical and organisational measures against unauthorised or unlawful processing, access, disclosure, copying, modification, storage, reproduction, display or distribution of Personal Data, and against accidental or unlawful loss, destruction, alteration, disclosure or damage of Personal Data.
4.2 Processor must implement such measures in accordance with Art. 32 of the General Data Protection Regulation ((EU) 2016/679), to ensure a level of security appropriate to the risk involved.
4.3 Controller hereby confirms that organisational and technical measures specified in Annex A are sufficient and appropriate under the Data Protection Legislation and this Agreement.
5.1 Processor will promptly and without undue delay notify Controller if any Personal Data is lost or destroyed or becomes damaged, corrupted, or unusable. Processor will restore such Personal Data at its own expense.
5.2 Processor will immediately and without undue delay notify Controller if it becomes aware of:
5.3 Where Processor becomes aware of (a) and/or (b) of clause 5.2, it shall, without undue delay, also provide Controller with the following information:
5.4 Immediately following any unauthorised or unlawful Personal Data processing or Personal Data Breach, the parties will coordinate with each other to investigate the matter. Processor will reasonably cooperate with Controller in Controller's handling of the matter, including:
5.5 Processor will not inform any third party of any Personal Data Breach without first obtaining Controller's prior written consent, except when required to do so by law.
5.6 Processor agrees that Controller has the sole right to determine:
5.7 Processor will cover all reasonable expenses associated with the performance of the obligations under clause 5.2 and clause 5.4 unless the matter arose from Controller's specific instructions, negligence, wilful default or breach of this Agreement, in which case Controller will cover all reasonable expenses.
6.1 Controller hereby authorises Processor to transfer or otherwise process Personal Data outside the Singapore or outside Singapore subject to conditions laid down in this Agreement.
6.2 Processor may only process, or permit the processing, of Personal Data outside the EEA under one of the following conditions:
6.3 If any Personal Data transfer between Controller and Processor requires execution of standard contractual clauses or equivalent under PDPA in order to comply with the Data Protection Legislation (where Controller is the entity exporting Personal Data to Processor outside the EEA), the parties will complete all relevant details and take all other actions required to legitimise the transfer.
7.1 Processor may not authorise a third party (subprocessor) to process the Personal Data unless all of the following conditions are met:
7.2 Controller hereby gives a general authorisation to involve subprocessors to process personal data under this Agreement. In the case Processor intends to update the list of subprocessors engaged, he must inform Controller and provide Controller with the opportunity to object against the intended changes.
7.3 Where the subprocessor fails to fulfil its obligations under such written agreement, Processor remains fully liable to Controller for the subprocessor's performance of its agreement obligations.
7.4 Where Processor fails to fulfil its guarantees under clause 7.1, it shall indemnify all of the Controller’s arising direct and indirect damages.
8.1 Processor must, at no additional cost, take such technical and organisational measures as may be appropriate, and promptly provide such information to Controller as Controller may reasonably require, to enable Controller to comply with:
8.2 Processor must notify Controller immediately and without undue delay if it receives any complaint, notice or communication that relates directly or indirectly to the processing of the Personal Data or to either party's compliance with the Data Protection Legislation.
8.3 Processor must notify Controller immediately and without undue delay when it receives a request from a Data Subject for access to their Personal Data or to exercise any of their related rights under the Data Protection Legislation.
8.4 Processor will give Controller its full cooperation and assistance in responding to any complaint, notice, communication or Data Subject request in connection with Personal Data processed.
8.5 Processor must not disclose the Personal Data to any Data Subject or to a third party other than at Controller's request or instruction, as provided for in this Agreement or as required by law.
9.1 This Agreement will remain in full force and effect so long as:
9.2 Any provision of this Agreement that expressly or by implication should come into or continue in force on or after termination of the Master Agreement in order to protect Personal Data will remain in full force and effect.
9.3 If a change in any Data Protection Legislation prevents either party from fulfilling all or part of its Master Agreement obligations, the parties will suspend the processing of Personal Data until that processing complies with the new requirements. If the parties are unable to bring the Personal Data processing into compliance with the Data Protection Legislation within 2 (two) months, they may terminate the Master Agreement on written notice to the other party.
10.1 At Controller's request, Processor will give Controller a copy of or access to all or part of Controller's Personal Data in its possession or control in the format and on the media reasonably specified by Controller.
10.2 On termination of the Master Agreement for any reason or expiry of its term, Processor will securely delete or destroy or, if directed in writing by Controller, return and not retain, all or any Personal Data related to this Agreement in its possession or control.
10.3 If any law, regulation, or government or regulatory body requires Processor to retain any documents or materials that Processor would otherwise be required to return or destroy, it will notify Controller in writing of that retention requirement, giving details of the documents or materials that it must retain, the legal basis for retention, and establishing a specific timeline for destruction once the retention requirement ends.
10.4 Processor will certify in writing that it has destroyed the Personal Data within 30 days after it completes the destruction.
11.1 If Controller is required to show its compliance with Data Protection Legislation, reasonably believes that a Personal Data Breach occurred or is occurring, or Processor is in breach of any of its obligations under this Agreement or any Data Protection Legislation, Processor will permit an assigned and eligible third-party representative of the Controller to audit Processor's compliance with this Agreement obligations, on at least 30 (thirty) days' notice, during the Term. Processor will give the third-party representative of the Controller all necessary assistance reasonably required to conduct such audits, provided that the audit concerns only the activities described in Annex A, and Controller and its third-party representatives keep confidentiality over the information obtained throughout the audit. The assistance may include, but is not limited to:
11.2 If a Personal Data Breach occurs or is occurring, or Processor becomes aware of a breach of any of its obligations under this Agreement or any Data Protection Legislation, Processor will:
11.3 Processor will promptly address any exceptions noted in the audit reports with the development and implementation of a corrective action plan by Processor's management.
11.4 Controller will cover all reasonable expenses incurred by Processor in connection with performing its obligations under clause 11.1.
Subject-matter and nature of processing: the provision of automation services for marketing on LinkedIn social network (https://linkedin.com, further referred to as “LinkedIn”), which requires the processing of personal data of LinkedIn registered users by Processor on behalf of Controller. The nature of the processing activities implies the search, collection, and structuring of information from the profiles of LinkedIn users, as well as the creation and automated sending of messages to LinkedIn users on behalf of Controller and/or Controller representatives.
Duration of Processing: duration of the Master Agreement.
Categories of data subjects: registered users of LinkedIn.
Purposes
Personal data categories:
To allow Controller to prepare and conduct LinkedIn marketing activities Profile photo, name, occupation, company, url, inbox messages, date and time of the message
To allow Controller to find people from its LinkedIn connections: Profile link, profile picture, full name, status (contact / new contact / ex-contact / connection sent) type of connection (1st / 2nd / 3rd), occupation, tags, connected since, campaign assigned, filter words from profile
To allow Controller to automate interactions with LinkedIn contacts:Inbox messages, connection status (contact / new contact / connect requested), message status (email required / no interaction / awaiting reply / replied) name of message recipient, date and time when the message was sent
To allow Controller to find people on LinkedIn Profile picture, name, occupation, company, url, post engagement, post author
To allow Controller to track the status of its connection requests on LinkedIn Profile picture, name, occupation, tags, actions
To allow Controller to sort its LinkedIn connections: Name, marketing campaign affiliation, tags, actions to be done
To allow Controller to integrate third-party tools: LinkedIn Controller data from Gro and a third-party tool: name, event, campaign, tags, target url, history, time delta, test
To allow Controller to import its LinkedIn contacts and blacklists to Processor’s platform: Contact id, first name, last name, profile link, job title, company name, email, phone, address, image link, tags, contact status, conversation status, object urn, public identifier, profile link public identifier, message thread link, invited at, connected at
To allow Controller to analyse whether a LinkedIn contact responded to its message positively: Conversation status (success / failure)
To allow Controller to export LinkedIn contacts found via Processor’s platform: Contact id, first name, last name, profile link, job title, company name, email, phone, address, image link, tags, contact status, conversation status, object urn, public identifier, profile link public identifier, message thread link, invited at, connected at
To allow Controller to analyse the efficiency of its social/marketing activities on LinkedIn Day-by-day (periodical) statistics, total statistics, communication statistics, campaign statistics, task statistics based on personal data listed above
Monitoring of API endpoints
Limitation and management of access rights to personal data
SSH protocol for accessing LinkedIn login data
2FA to employee accounts
2FA feature for user accounts
Database encryption at-rest
VPN for accessing servers
Secure (https://) connection
Compliance with password protection and management, access control policies
Usage of antivirus software and firewalls
Employees are aware of and trained on their respective data protection responsibilities
Regular back-ups of the data processed
| Name | Services Provided | Location |
|---|---|---|
| AWS | Cloud hosting provider | Singapore/US |
| Unipile | App-to-app integration to allow Controller to connect third-party tools to Processor’s platform | The United States |
| Clerk | A third-party service specializing in user authentication and management | The United States |
| Intercom | Helps support teams streamline communication and engagement with customers across email, chat, and social media channels. | US/Ireland |
| Stripe | Acts as a payment processor and financial infrastructure provider, enabling businesses to accept online and in-person payments | The United States |
| Mistral AI | LLM service | France |
| Cloudflare | Network security, performance, and reliability services | The United States |
| MongoDB Atlas | A fully managed, multi-cloud database service built on Mongo database | Singapore/US |
Get Started
Start free and get 100 leads on us. Join thousands of sales professionals already using Gro to automate LinkedIn outreach and close more deals.