Data Processing Agreement (DPA)

SYNTRO Marine™

Effective Date: [03/16/2026]

This Data Processing Agreement ("DPA") governs the processing of personal data by SYNTRO Marine™ when providing services to businesses using the platform.

This agreement forms part of the Terms and Conditions of SYNTRO Marine™.

1. Roles of the Parties

For the purposes of applicable data protection laws:

Customer (Marina, Dealer, Service Provider)
acts as the Data Controller

SYNTRO Marine™ / Momentum Business Solutions
acts as the Data Processor

The Customer determines the purpose and use of data, while SYNTRO Marine™ processes the data to provide the platform services.

2. Types of Data Processed

The platform may process various categories of data including:

Customer Information

• names
• email addresses
• phone numbers
• billing information

Vessel Data

• vessel make and model
• hull identification numbers (HIN)
• service history
• maintenance records

Operational Data

• service orders
• parts inventory records
• technician assignments
• scheduling records

3. Purpose of Data Processing

SYNTRO Marine™ processes data solely to provide the Services including:

• vessel service management
• marina operations support
• customer communication
• service scheduling
• maintenance record storage
• platform analytics and improvement

We process data only as instructed by the Customer.

4. Security Measures

SYNTRO Marine™ maintains security controls designed to protect customer data, including:

• encrypted communication channels
• secure cloud infrastructure
• restricted access controls
• system monitoring and logging
• authentication safeguards

These safeguards help protect against unauthorized access, loss, or misuse of data.

5. Subprocessors

SYNTRO Marine™ may use trusted subprocessors for services such as:

• cloud hosting providers
• payment processors
• messaging systems
• analytics tools

All subprocessors are required to maintain appropriate data protection standards.

6. Data Retention

Customer data is retained only as long as necessary to:

• provide the Services
• comply with legal obligations
• resolve disputes
• enforce contractual agreements

Customers may request deletion of their data upon account termination where permitted by law.

7. Data Subject Rights

Where applicable law provides rights to individuals regarding their personal data, the Customer is responsible for responding to such requests.

SYNTRO Marine™ will assist Customers in fulfilling lawful requests when required.

8. Data Breach Notification

In the event of a confirmed data breach affecting Customer data, SYNTRO Marine™ will:

• investigate the incident
• notify affected customers without undue delay
• take appropriate steps to mitigate the breach

9. International Data Transfers

Customer data may be stored and processed in data centers located in the United States or other jurisdictions where our infrastructure providers operate.

Appropriate safeguards will be maintained for such transfers.