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GDPR Article 28 Compliant

Data Processing Agreement

How we process personal data on behalf of our customers.

This Data Processing Agreement ("DPA") forms part of the agreement between AI Publisher ("Processor", "we", "our", "us") and the customer using AI Publisher ("Controller", "Customer").

This DPA governs processing of personal data carried out through the Service.

Effective Date: April 1, 2026

Last Updated: April 1, 2026

Processor

AI Publisher — the party processing data on behalf of the Controller.

Controller

The Customer — the party determining why and how personal data is processed.

1. Purpose of This Agreement

This Agreement applies where we process personal data on behalf of customers while providing SaaS and AI-based services. It defines:

  • Processing responsibilities
  • Security obligations
  • Confidentiality duties
  • Data transfer safeguards

2. Definitions

Personal Data

Any information relating to an identified or identifiable individual.

Processing

Any operation performed on personal data including collection, storage, analysis, transmission, or deletion.

3. Scope of Processing

We process data only as necessary to provide the Service. Processing may include:

  • Account management
  • AI prompt handling
  • File processing
  • Output generation
  • Technical support
  • Usage logging

4. Categories of Data Processed

Data may include:

NamesEmail addressesAccount identifiersUploaded textPromptsGenerated outputsTechnical logs

5. Categories of Data Subjects

Data subjects may include:

  • Customer employees
  • End users
  • Business contacts
  • Client representatives

6. Processing Instructions

We process personal data only:

  • Under documented customer instructions
  • As required for service delivery
  • Where legally required

7. Confidentiality Obligations

All personnel with access to personal data must be bound by confidentiality obligations. Access is restricted to authorized personnel only.

8. Security Measures

We implement commercially reasonable safeguards including:

  • Encryption in transit
  • Secure storage
  • Access controls
  • Authentication protection
  • Activity monitoring

Infrastructure may use secure providers such as Amazon Web Services and Google Cloud.

9. Use of Subprocessors

We may engage subprocessors necessary for service delivery. Examples may include:

  • Hosting providers
  • Payment processors
  • Analytics providers
  • Infrastructure providers

Customers may request a current subprocessor list.

10. Subprocessor Safeguards

All subprocessors must be contractually required to maintain equivalent data protection obligations.

11. International Data Transfers

Where data is transferred outside the EU, lawful safeguards apply including:

  • Standard Contractual Clauses (SCCs)
  • Approved transfer mechanisms

This is required under GDPR for all cross-border data transfers.

12. Assistance with Data Subject Rights

We assist customers where reasonably necessary to respond to:

  • Access requests
  • Deletion requests
  • Correction requests
  • Portability requests
  • Restriction requests

13. Security Incident Notification

If a personal data breach affecting customer data occurs, we will notify the customer without undue delay. Notification will include:

Nature of Incident

Likely Impact

Corrective Actions

14. Audit Rights

Where legally required, customers may request reasonable information demonstrating compliance. Formal audits must be:

  • Proportionate
  • Reasonable
  • Subject to confidentiality

15. Data Retention and Deletion

Upon account termination or instruction:

Personal data will be deleted or returned unless retention is legally required.

16. AI Processing Clarification

Where AI features are used:

Submitted prompts and files may be processed solely to deliver requested outputs. No unrelated resale of customer content occurs.

17. Legal Requests

If legally compelled to disclose data, we will notify the customer unless prohibited by law.

18. Liability Relationship

Liability under this DPA follows the main service agreement unless otherwise agreed.

19. Term and Duration

This DPA remains effective while personal data is processed through the Service.

20. Governing Law

This DPA follows the governing law selected in the main Terms of Service.

21. Contact for Data Protection Matters

Email: privacy@aipublisher.com

Enterprise Assurance

Customer data is processed only for service delivery under documented safeguards and contractual confidentiality obligations.

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