Effective Date: 2026.01.01
This Intercompany Data Processing Agreement (the “Agreement”) governs the internal sharing and processing of information between MaxFusion Group Inc. and its affiliated entities for purposes of facilitating operational coordination, digital infrastructure services, and business administration across the MaxFusion Group ecosystem.
This Agreement forms part of the MaxFusion Group data governance framework and should be read together with the following policies and agreements:
Collectively these documents form the MaxFusion Group Data Governance Framework.
This Agreement is entered into between the following entities (collectively referred to as the “Group Companies”):
MaxFusion Group Inc.
Hanson Energy Inc.
ReFusion Recycling Inc.
Inquill Agency LLC
together with any subsidiary, affiliated entity, or operational division that may from time to time become part of the MaxFusion Group ecosystem.
Each entity may be referred to individually as a “Group Entity” and collectively as the “Group Companies.”
The purpose of this Agreement is to establish a structured framework governing how information may be exchanged, processed, and managed between Group Companies in order to facilitate legitimate business operations across the MaxFusion ecosystem.
Such cooperation may include activities such as:
The Group Companies acknowledge that certain information processed in the course of these activities may include personal information relating to business contacts, representatives of partner organizations, employees, contractors, or other individuals interacting with the Group Companies.
This Agreement establishes the responsibilities of each Group Entity with respect to the processing of such information.
Each Group Entity shall act as a Data Controller with respect to personal information that it collects directly in connection with its own business activities.
This includes information collected through its own websites, communications, contractual engagements, operational systems, and business relationships.
Each Group Entity shall determine the purposes and means by which such information is processed, subject to the requirements of applicable data protection laws and the policies forming part of the MaxFusion Group Data Governance Framework.
MaxFusion Group Inc. shall provide group-level governance and oversight for data protection practices across the Group Companies.
This governance function includes coordinating privacy policies, maintaining group-level compliance frameworks, overseeing vendor disclosure practices, and ensuring consistent data protection practices across affiliated entities.
MaxFusion Group Inc. may also act as a Data Controller for certain categories of information processed at the group level, including strategic partnership communications, investment relationships, and group administrative functions.
Inquill Agency LLC may operate certain digital infrastructure systems, marketing platforms, automation tools, analytics systems, or other digital services used by the Group Companies.
Where Inquill Agency LLC processes personal information solely on behalf of another Group Entity in connection with such services, Inquill Agency LLC shall act as a Data Processor and shall process such information only in accordance with the instructions of the relevant Data Controller.
Such processing may include operation of:
Information may be shared between Group Companies where reasonably necessary to support legitimate operational activities within the MaxFusion ecosystem.
Such sharing may occur in circumstances including but not limited to:
Each Group Entity shall limit internal sharing of information to what is reasonably necessary for the relevant operational purpose.
The Group Companies shall implement reasonable technical and organizational safeguards designed to protect personal information from unauthorized access, disclosure, or misuse.
Such safeguards may include encryption, authentication systems, access controls, security monitoring tools, and internal policies governing the handling of sensitive information.
Access to shared data within the Group ecosystem shall be restricted to personnel whose access is necessary for the performance of their duties.
Where third-party vendors are used to support infrastructure or digital services operated by the Group Companies, such vendors may process information as sub-processors acting under the authority of the relevant Data Controller or Processor.
The categories of such vendors are described in the MaxFusion Group Sub-Processor Disclosure, which forms part of the Group’s data governance framework.
The retention and lifecycle management of information processed under this Agreement shall follow the practices described in the MaxFusion Group Data Retention and Data Lifecycle Policy.
Each Group Entity shall ensure that information is retained only for as long as reasonably necessary to fulfil operational, contractual, or legal requirements and shall implement procedures for the secure deletion or anonymization of data when retention is no longer necessary.
Where a Group Entity provides services that involve processing personal information on behalf of an external client or partner, such processing shall be governed by a separate Data Processing Addendum (DPA) entered into between the relevant Group Entity and the external client.
In particular, Inquill Agency LLC may process personal information on behalf of clients in connection with digital marketing systems, CRM platforms, automation systems, SaaS platforms, and related services.
Such processing shall be governed by the Inquill Agency Client Data Processing Addendum, which is incorporated by reference into the MaxFusion Group data governance framework.
The Group Companies shall process personal information in accordance with applicable data protection laws and regulations that may apply to their operations, including but not limited to:
Each Group Entity shall be responsible for ensuring compliance with applicable legal obligations within the jurisdictions in which it operates.
MaxFusion Group Inc. may update this Agreement from time to time in order to reflect changes in the Group’s corporate structure, operational practices, or applicable legal requirements.
Updated versions of this Agreement shall be made available to the Group Companies and incorporated into the MaxFusion Group data governance framework.
Questions regarding this Agreement or the MaxFusion Group data governance framework may be directed to:
legal@maxfusiongroup.com
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