By signing up for or using our services, you ("Client") agree to the terms of this Data Processing Agreement ("DPA"). This DPA forms part of our Terms of Service and is binding on all clients.

1. Purpose

ICNXN (owned and operated by BOSIO LLC) ("Service Provider," "we," "us") provides marketing and CRM services using the ICNXN platform. As part of these services, we administer a sub-account on the platform on your behalf and may access personal data you have collected about your own customers and contacts ("End User Data"). This DPA sets out how we handle that data.

2. Our Role

We act as a Data Processor with respect to End User Data held in your sub-account. You remain the Data Controller — you decide why and how your customers' data is collected and used. We only process it to deliver the services you've engaged us for.

3. What We Will and Won't Do With Your Data

We will only access your sub-account data to:

- Set up and manage your platform sub-account

- Build and run campaigns, automations, and workflows on your behalf

- Provide technical support at your request

- Generate reports and analytics for you

- Carry out any other task you expressly instruct us to perform

We will not:

- Access your customers' data for any purpose beyond delivering your services

- Use your customers' data for our own marketing or business development

- Sell, share, or transfer your customers' data to any third party without your written consent

- Combine your customers' data with data from other clients or external sources

- Retain your customers' data after our service relationship ends, except as required by law

4. Your Obligations as Data Controller

By using our services, you confirm that:

- You have the legal right to collect the End User Data in your sub-account

- Your customers have been given appropriate notice (e.g., via your own privacy policy) that their data may be handled by a third-party service provider

- You will not instruct us to process data in a way that violates applicable law

- You maintain your own privacy policy and obtain necessary consents from your customers

5. Security

We implement reasonable technical and organisational measures to protect End User Data we access, including limiting sub-account access to authorised personnel only and using secure credentials for platform access.

6. Data Breach Notification

If we become aware of a breach involving your End User Data, we will notify you within 72 hours of becoming aware, including details of what occurred and steps being taken. You are responsible for determining your notification obligations to regulators and your customers under applicable law.

7. Platform Sub-Processor

You acknowledge that End User Data is stored and processed on the ICNXN platform (operated by BOSIO LLC / GoHighLevel). By using our services, you consent to this. ICNXN's data handling is governed by its own Privacy Policy and Terms of Use at icnxn.com.

8. Data Subject Rights

If your customers contact us directly to exercise privacy rights (access, correction, deletion, etc.), we will forward the request to you promptly and provide reasonable assistance. You are responsible for responding to those requests.

9. Retention and Deletion

We retain End User Data only as long as needed to perform your services. When our engagement ends, we will cease accessing your sub-account and delete any copies of End User Data in our possession outside the platform. Your data within the ICNXN platform remains under your control and it is your responsibility to manage it after our engagement ends.

10. Australian Clients

Where End User Data relates to individuals in Australia, both parties agree to comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) in their respective roles. We acknowledge our obligations as a contracted service provider under the APPs.

11. US Clients

Where End User Data relates to California residents, we confirm we are acting as a "service provider" under the CCPA and will not use California consumer data for any purpose beyond performing your services. Similar obligations apply for other US states with applicable privacy laws.

12. Acceptance

By signing up for or continuing to use our services, you confirm that you have read, understood, and agree to this Data Processing Agreement. If you do not agree, you must not use our services.

If you require a separately signed version of this DPA for your own compliance purposes, please contact us at [email protected].

13. Updates

We may update this DPA from time to time. We will notify you of material changes by email or through the platform. Continued use of our services after notice of changes constitutes acceptance of the updated DPA. The current version is always available at icnxn.com/legal/data-processing-agreement.

14. Contact

For any questions about this DPA:

ICNXN (BOSIO LLC)
ATTN: Legal Department
9169 W State St #2836
Garden City ID 83714
Email: [email protected]
Website: http://icnxn.com.