FTC Safeguards Rule & GLBA DPA Addendum

Data Processing Agreement (DPA)

This Data Processing Addendum ("DPA") forms an integral part of the LeuBooks Terms of Service between LeuBooks CPA ("Processor") and subscribing CPA Practices ("Controller").

1. Roles & Legal Regulatory Framework

Under applicable US privacy and financial laws (FTC Safeguards Rule, GLBA, and state privacy acts):

CPA Practice (Data Controller)

The CPA practice acts as Data Controller, retaining full responsibility for client consent and accounting instructions.

LeuBooks Platform (Data Processor)

LeuBooks acts as Data Processor, processing Non-Public Financial Information ("NPI") strictly to deliver software hosting and financial ledger services.

2. Security Obligations & Breach Notifications

LeuBooks maintains technical and administrative measures protecting client records against unauthorized disclosure. In the event of a verified security incident affecting customer data, LeuBooks will notify affected CPA Firm Administrators without undue delay (and within 72 hours of verification).

3. Data Export & Permanent Purging

Upon account termination, LeuBooks provides self-service CSV and PDF export options for all financial ledgers, journal entries, and client documents. Following a 30-day graceful transition window, production data is permanently purged.