1. Purpose

This Data Processing Notice summarizes how Qorvello Cleaning Services processes personal data on behalf of customers where applicable and how third-party processors are engaged in compliance with GDPR Article 28.

2. Roles

Qorvello Cleaning Services acts as a Data Controller for customer data collected directly.
In limited circumstances (e.g., commercial contracts), Qorvello may act as a Data Processor when processing personal data on behalf of a commercial client.

3. Processing Instructions

Where acting as a Processor, Qorvello shall:

Process data only on documented instructions from the Controller.
Ensure personnel confidentiality obligations.
Implement appropriate technical and organizational security measures.
Assist the Controller in responding to data subject requests where applicable.
Delete or return personal data at contract termination, unless legally required to retain it.

4. Subprocessors

We may engage subprocessors for:

Cloud hosting
Payment processing
CRM systems
Analytics platforms
Email delivery services

Subprocessors are contractually bound by data protection obligations consistent with GDPR Article 28.

5. International Transfers

If subprocessors are located outside the EEA, appropriate safeguards (e.g., Standard Contractual Clauses) are implemented.

7) ADVERTISING & MARKETING DISCLOSURE

Effective Date: [Insert Date]

1. General Advertising Transparency

Qorvello Cleaning Services may advertise through:

Search engines
Social media platforms
Content discovery platforms (including Reddit, Quora, Outbrain)
Display advertising networks

All advertising materials are intended to comply with:

FTC Truth-in-Advertising standards
EU Unfair Commercial Practices Directive
Platform-specific advertising policies

We do not make false, deceptive, or unsubstantiated claims.

2. No Exaggerated Claims

We do not guarantee:

Permanent cleaning results
Elimination of environmental hazards
Mold remediation or biohazard removal unless specifically contracted
Health improvements

Cleaning outcomes depend on property condition and service scope.

3. Sponsored Content Disclosure

Where required by law or platform policy, advertisements and sponsored placements are clearly identified as promotional content.

4. Affiliate Disclosure (If Applicable)

If affiliate relationships are established in the future, appropriate disclosure statements will be added in accordance with FTC guidelines.

8) ACCESSIBILITY STATEMENT

Effective Date: [Insert Date]

1. Commitment to Accessibility

Qorvello Cleaning Services is committed to ensuring digital accessibility consistent with:

Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards
ADA accessibility principles (where applicable)

2. Ongoing Improvements

We continuously review our website to improve accessibility, including:

Screen reader compatibility
Alternative text for images
Logical navigation structure

3. Feedback

If you encounter accessibility barriers, please contact:

[email protected]
+1 831-586-9742

We will make reasonable efforts to address concerns.

9) SERVICE TERMS & CONDITIONS (CLIENT AGREEMENT SUMMARY)

Effective Date: [Insert Date]

1. Scope of Work

Services are limited to those expressly agreed upon in writing or booking confirmation. Any additional services require approval and may incur additional charges.

2. Client Responsibilities

Clients must:

Provide safe access to premises
Secure pets
Disclose known hazards
Remove fragile or valuable items

3. Property Condition Disclaimer

We are not responsible for:

Pre-existing damage
Structural defects
Normal wear and tear
Damage resulting from undisclosed hazards

4. Health & Safety

We reserve the right to refuse or discontinue service if conditions pose safety risks.

5. Force Majeure

We are not liable for delays or failure due to events beyond reasonable control, including:

Severe weather
Government restrictions
Utility outages

10) COMPLAINTS & DISPUTE RESOLUTION POLICY

Effective Date: [Insert Date]

1. Internal Resolution

Customers are encouraged to contact us first to resolve concerns:

Email: [email protected]
Phone: +1 831-586-9742

We aim to respond within 5 business days.

2. Escalation

If resolution is not achieved:

U.S. customers may pursue remedies under applicable state law.
EU customers retain the right to lodge complaints with relevant supervisory authorities.

3. Alternative Dispute Resolution (EU Consumers)

Where applicable under EU consumer law, consumers may use Online Dispute Resolution (ODR) platforms.

4. Governing Law

Disputes are governed by the laws of West Virginia, USA, unless mandatory consumer protection laws require otherwise.

11) DATA BREACH RESPONSE NOTICE

Effective Date: [Insert Date]

1. Incident Response

In the event of a personal data breach, Qorvello will:

Assess the scope and risk
Mitigate harm
Notify affected individuals when legally required
Notify supervisory authorities where required under GDPR Article 33

2. Notification Timeline

Where GDPR applies, notification to authorities will occur within 72 hours of awareness when required.

3. Documentation

All incidents are documented internally in accordance with accountability obligations.

12) ANTI-SPAM POLICY

Effective Date: [Insert Date]

1. Consent-Based Marketing

Marketing emails are sent only where:

Consent has been obtained; or
Existing customer relationship permits lawful communication under applicable law.

2. Opt-Out

All marketing emails include an unsubscribe mechanism.

Unsubscribing does not affect transactional communications.

3. No Purchased Lists

We do not purchase third-party email lists for marketing purposes.