360nook360nook.com

360Nook — Data Processing Agreement

Last updated: 11 September 2026

1. The two roles

You are the controller of the personal data you load into your workspace — your contacts, their messages, their bookings. You decide what to collect and why.

We are the processor. We hold that data on your instructions and do not decide what to do with it.

Separately, we are the controller of your own account data — your name, your email address, your plan and your usage. That is covered by the Privacy Policy, not by this agreement.

If you are an agency with sub-accounts, you are the controller for your clients' workspaces as between you and us, and responsible to your clients for how their data is used.

2. What we process, and why

CategoryExamplesWhy
Contact recordsNames, emails, phone numbers, addresses, tags, custom fields, notesTo provide the CRM
Message contentEmails, SMS and chat messages sent and receivedTo deliver and display conversations
Appointment dataBookings, booking-form answers, marketing consent and its wordingTo run calendars and booking pages
FilesAnything uploaded to Media StorageTo store and serve them
Form and survey submissionsWhatever your forms collectTo capture and route them
Payment recordsOrders, invoices, subscriptions, transactionsTo run the commerce features

We process it only to provide the Service, to keep it secure, and where you instruct us to. We do not sell it, and we do not use your contacts or their messages to train AI models.

3. Duration

For as long as your account is open, and afterwards only as long as section 7 describes.

4. Your instructions

Using the Service is your instruction to process the data in it. If you give us an instruction that we believe breaks data-protection law, we will tell you rather than carry it out.

5. Confidentiality

Everyone with access to your data is bound to keep it confidential.

6. Sub-processors

We use the companies below. This list is what the platform actually calls, and you can check it against the product. A sub-processor list that is wrong is worse than none.

Sub-processorPurposeWhat reaches themWhere
AnthropicAI features you enableConversation messages and prompts sent to AI featuresUnited States
OpenAIAI features you enableAs aboveUnited States
GoogleAI features you enableAs aboveUnited States
BrevoEmail deliveryRecipient address, subject and body of each email sentEU
TwilioSMS, voice and phone numbersPhone numbers, message content, call metadataUnited States
Your chosen payment gatewayPayments you takePayment and customer details, handled by them directlyVaries
Our own server infrastructureHostingEverything, at restThailand

Three things worth stating plainly about that list:

Where you connect an integration yourself — a social account, another CRM, a calendar — that service receives data on your instruction. It is your sub-processor, not ours.

We will give you notice of a new sub-processor before it starts processing your data, so that you can object.

7. Deletion and return

8. International transfers

Our servers are in Thailand. Several sub-processors in section 6 operate outside it, so enabling those features transfers personal data internationally.

We have not yet put Standard Contractual Clauses in place. If you are in the EU or UK, or your contacts are, this is the section to take to your own adviser before relying on the Service for that data. We would rather you read it here than find out afterwards.

9. Security

As implemented, not as aspiration:

We hold no security certification — no ISO 27001, no SOC 2. If your procurement process requires one, we do not meet it today.

10. Breach notification

If we become aware of a personal data breach affecting your data, we will tell you without undue delay and within 72 hours of becoming aware of it, with what we know: what happened, which data, and what we are doing about it.

We will tell you even where we are not sure of the full extent yet. A late complete report is worse than a prompt partial one, because you may have your own notification deadline running.

11. Helping you meet your obligations

We will give you reasonable help with:

12. Audits

We will answer reasonable written questions about our processing. We do not currently offer on-site audits.

13. Liability

Liability under this agreement is subject to the limits in the Terms of Service.

14. Contact

[email protected]