Data Processing Agreement

Roles

Where your workspace content contains personal data, you are the controller and TO BE COMPLETED — registered company name is the processor. You decide what goes in and why; we process it to run the service for you.

This agreement forms part of our Terms of Service and applies automatically. You do not need to sign a separate copy, though we will sign one if your procurement requires it.

What we process

• Subject matter — providing the Coldcache service.
• Duration — for as long as your workspace exists, plus the retention period on your plan.
• Nature and purpose — storing agent configuration and run records, and transmitting prompts to the model provider you selected in order to produce an answer.
• Types of personal data — whatever your users put into prompts and documents, plus account identifiers and billing contacts. You control this; we cannot predict it.
• Categories of data subjects — your personnel, and any individual referred to in content your users submit.

Our obligations

We will:

• Process personal data only on your documented instructions, including on transfers, unless law requires otherwise — in which case we will tell you first, if permitted.
• Ensure anyone we authorise to process it is bound by confidentiality.
• Implement appropriate technical and organisational measures under Article 32, including encryption in transit, hashed credentials, and per-agent access control.
• Notify you without undue delay after becoming aware of a personal data breach, with enough information for you to meet your own notification duties.
• Assist you with data subject requests, and with data protection impact assessments and prior consultations, taking account of the nature of the processing.
• Delete or return personal data at the end of the service, at your choice, except where law requires retention.
• Make available the information needed to demonstrate compliance and allow for audits, including inspections, by you or an auditor you mandate.

Sub-processors

You give general authorisation for us to engage the sub-processors listed on this page. We will give you notice before adding or replacing one, and you may object on reasonable data-protection grounds.

Each sub-processor is bound by data protection obligations no less protective than these. We remain fully liable to you for their performance.

The current list is published below and maintained as part of this document.

International transfers

The model providers process data in the United States. Those transfers rely on the European Commission's Standard Contractual Clauses, together with supplementary technical and organisational measures, and a transfer impact assessment we will share on request.

If your agent versions name only providers in a particular region, that is where your prompts go. The provider is a property of the pinned version and is recorded on every run, so this is auditable rather than assumed.

What we never do

We do not train models on your content. We do not sell it. We do not use it for any purpose other than running the service for you and meeting a legal obligation.

Sub-processors