Legal Document
Data Processing Agreement
The compliance document a partner's legal team will actually require — regardless of how relationship-based our model is.
Version 1.0 · Effective September 2026
Why This Exists
JustUs stores seeker conversation data, contact information, and spiritual journey records. Under CCPA and GDPR, larger partners legally require a signed DPA from any vendor processing personal data on their behalf. This isn't a sales objection — it's a compliance requirement their legal team enforces.
Compliance Coverage
- ✓CCPA (California Consumer Privacy Act) — applies to California residents whose data is processed
- ✓GDPR (General Data Protection Regulation) — applies to EU/UK residents whose data is processed
- ✓This DPA satisfies the Article 28(3) GDPR requirement for a written data processing agreement
- ✓This DPA satisfies the CCPA requirement for a service provider contract that limits data use
1. Roles & Scope
Customer (Data Controller)The church or ministry that determines the purposes and means of processing seeker data. The Customer owns all personal data submitted through their JustUs account.
JustUs (Data Processor)JustUs processes personal data on behalf of the Customer, strictly per the Customer's instructions through the platform's configuration.
Data CategoriesSeeker names, email addresses, phone numbers, location (city/state), conversation content, spiritual journey stage, and escalation preferences.
Processing PurposesProviding AI-guided spiritual conversations, routing escalations to church staff, tracking discipleship progress, and generating ministry analytics for the Customer.
Product ImprovementJustUs may use de-identified, aggregated conversation analytics — such as topic patterns, engagement trends, and escalation rates — to improve the effectiveness of AI conversations across all partner accounts. Individual conversation content, seeker names, contact information, and church-identifiable details are never used for product improvement and cannot be re-identified from the aggregated data.
2. Sub-Processors
AI ProviderOpenAI / Anthropic / Google — processes conversation content to generate AI responses. Data is transmitted via API and not retained by the AI provider for training purposes when configured per our settings.
InfrastructureAWS / Base44 platform — hosts the application database, file storage, and backend services. SOC 2 compliant infrastructure.
NotificationsOneSignal (push notifications), email service (SMTP) — delivers escalation alerts to church staff.
PaymentsStripe — processes subscription payments. Does not have access to seeker conversation data.
Sub-Processor ChangesJustUs provides 30 days notice before engaging a new sub-processor. Customer may object to a new sub-processor by terminating the agreement.
3. Security Measures
EncryptionData encrypted in transit (TLS 1.2+) and at rest (AES-256). Database connections use SSL.
Access ControlRole-based access. Only the Customer's church leaders and authorized JustUs support staff can access the Customer's data. All access is logged.
AuthenticationPassword hashing (bcrypt), session management, and optional 2FA for admin accounts.
Infrastructure SecurityHosted on SOC 2 Type II compliant cloud infrastructure with regular security patching.
PersonnelJustUs team members with data access are trained on data privacy and subject to confidentiality agreements.
4. Data Subject Rights
AccessCustomer can export all seeker data from their Ministry Hub at any time via the data export tool.
DeletionCustomer can delete individual seeker records or request bulk deletion of all data at any time. Deletion is permanent within 30 days.
RectificationCustomer can edit seeker information directly in the Ministry Hub.
PortabilityCustomer can export all data in JSON or CSV format for transfer to another system.
Handling RequestsJustUs assists Customer with data subject requests when the request is routed through the Customer. JustUs does not interact directly with seekers regarding data rights.
5. Breach Notification
Notification TimelineJustUs notifies Customer of a confirmed personal data breach within 72 hours of discovery, including the nature of the breach, data affected, and remediation steps.
Customer ObligationCustomer is responsible for notifying affected seekers (data subjects) as required by applicable law. JustUs provides reasonable assistance with the notification.
DocumentationJustUs documents all breaches, including facts, effects, and remediation, and makes this documentation available to Customer and regulators upon request.
6. Retention & Deletion
Active SubscriptionData is retained for the duration of the Customer's active subscription. The Customer controls deletion at any time.
Post-TerminationWithin 30 days of subscription termination, JustUs deletes all Customer personal data unless legally required to retain it longer.
BackupsEncrypted backups may contain residual data for up to 90 days post-deletion. Backups are access-restricted and overwritten on a rolling schedule.
Anonymized DataJustUs may retain fully anonymized, aggregated statistics (e.g., total conversation counts) that cannot be re-identified.
7. Cross-Border Data Transfers
Data LocationCustomer data is stored in US-based data centers (AWS us-east-1). EU/UK customer data may be transferred to the US under Standard Contractual Clauses (SCCs).
SCCsJustUs provides signed Standard Contractual Clauses for any transfer of EU/UK personal data to the US, upon request.
This DPA is incorporated by reference into the Master Services Agreement.
The full legal text is available on request. Contact your JustUs partnership coordinator.