This Data Processing Agreement applies where it is incorporated into a signed services agreement, order form, statement of work, or other written agreement between Sendrato Australia Pty Ltd and a customer.
1. Roles
For customer-controlled event data, the customer is generally the controller or responsible entity, and Sendrato processes that data to provide the Ludo Leisure Suite. For account, security, billing, fraud, and legal compliance data, Sendrato may act as an independent controller or responsible entity.
2. Processing instructions
Sendrato processes customer data to provide, secure, support, improve, and administer Ludo services, and to comply with law, payment partner rules, fraud controls, and signed customer instructions.
3. Customer obligations
The customer is responsible for having a lawful basis to collect and provide personal information to Sendrato, giving required notices, obtaining required consents, and ensuring event data supplied to Ludo is accurate.
4. Security measures
Sendrato uses technical and organisational measures designed to protect customer data, including TLS encryption in transit, encryption for sensitive stores, role-based access controls, multi-factor authentication for administrative accounts, logging, and access review.
5. Sub-processors
Sendrato may use sub-processors to provide hosting, database, storage, email, analytics, app distribution, customer support, and payment-related services. Current sub-processor categories are listed in the Privacy Policy.
6. Assistance
Sendrato will provide reasonable assistance with privacy requests, regulator enquiries, security incidents, and customer audits where the request relates to Ludo services and is reasonable in scope.
7. Deletion and return
At the end of an engagement, Sendrato will delete, de-identify, or return customer data according to the signed agreement, unless retention is required or permitted by law, payment partner rules, audit obligations, financial crime controls, or dispute handling.
8. Conflict
If this Data Processing Agreement conflicts with a signed services agreement, the signed services agreement prevails.