1 · Roles

Your organisation is the controller of your readers' personal data. AM Consulting LLC, doing business as DITA ("DITA"), is the processor, acting only on your documented instructions. Using the platform as described in the terms of service constitutes those instructions.

2 · Subject matter and duration

We process reader data for as long as your library exists, plus 30 days after cancellation. The purpose is operating a digital library: enrolling readers, lending titles, syncing reading position, and reporting usage to you in aggregate.

3 · Categories of data subject

• Readers with accounts, including staff and students where applicable.
• Readers who joined from a printed code, for whom we hold no identifying information.
• Administrators and librarians who operate your library.

4 · Categories of personal data

• Identifiers: email address or directory identity, where the library collects one.
• Usage: loans, returns, reading position, bookmarks and notes.
• Technical: authentication records and security logs.

We do not process special category data. The platform has no field for it and no integration that would supply it.

5 · Our obligations

• Process only on your instructions, and tell you if an instruction appears to breach applicable law.
• Ensure anyone with access is bound by confidentiality.
• Apply appropriate technical and organisational measures, including encryption in transit and at rest and two-factor authentication for administrative access.
• Assist you in responding to data subject requests — although the admin screens let you handle most of them yourself, immediately.
• Assist with data protection impact assessments and with regulator engagement where relevant.
• Delete or return data at the end of the agreement, at your choice.
• Make available the information needed to demonstrate compliance, and allow audits on reasonable notice.

6 · Sub-processors

We use sub-processors for hosting, storage and payment. They are bound by equivalent obligations. We will tell you before adding or replacing one, and you may object.

The current list is available on request and will be published here once the review is complete.

7 · International transfers

Reader data stays in the hosting region chosen when your library is set up. Where a transfer outside that region would otherwise be necessary, it does not happen without your instruction and an appropriate legal mechanism.

8 · Breach notification

If we become aware of a personal data breach affecting your readers, we will notify you without undue delay and in any event within 72 hours, with what we know at the time and what we are doing about it. We will not wait until the picture is complete.

9 · Return and deletion

At any point you can export catalogue records, collections, reader list and loan history in open formats. On termination we delete reader data after the 30-day recovery window, or return it first if you ask.

10 · Signature

If your governance process needs this signed as a standalone document, ask and we will send an executable copy.