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Data Processing Agreement

Effective from the date the hosted service launches

This agreement forms part of the Terms of Service between ShichifukuTekx FZE, of Office C1-1F-SF10837, Ajman Free Zone C1 Building, Ajman, United Arab Emirates ("Hivelock"), and the customer using the hosted version of Hivelock ("Customer"). It covers personal data in Customer Content.

1. Roles

2. Instructions

Hivelock processes personal data only on Customer's documented instructions, unless the law requires otherwise. The Terms, this agreement, and Customer's use of the Service and its settings are those instructions. Hivelock will tell Customer if it believes an instruction breaks data protection law.

3. Confidentiality

People who may access personal data must be bound by confidentiality.

4. Security

Hivelock will keep the technical and organisational measures in Annex 2, and may improve them. Customer is responsible for its own settings, users, credentials and connections. There has been no independent security review or penetration test yet, and Hivelock holds no security certification.

5. Subprocessors

Model Providers and Connected Services are not subprocessors. Customer chooses them, holds the account and key, and sends data to them through its own configuration. Customer is responsible for its agreements with them.

6. Help with data subject requests

Hivelock will pass on any request it receives about Customer's data, and will not answer it unless instructed or required by law. Customer can use the Service to find, change and delete most data, and export it. Where that is not enough, Hivelock will give reasonable help at no extra charge.

Current limits Customer should know about:

7. Personal data breaches

Hivelock will tell Customer without undue delay, and within 72 hours, after becoming aware of a personal data breach affecting Customer's data. It will give what is known about the breach, and what is being done, and update Customer as it learns more. Customer decides whether to notify regulators and individuals.

8. Help with assessments

Hivelock will give reasonable help with data protection impact assessments and regulator consultations, given the nature of the processing and the information it has.

9. International transfers

Hosting region: United Arab Emirates. Where personal data moves out of the EEA, UK or another restricted area, the parties will use a lawful transfer mechanism, such as the EU standard contractual clauses and the UK addendum.

10. Return and deletion

11. Audits

Hivelock will give the information reasonably needed to show it meets this agreement, starting with the security overview. There is no third-party report yet. Further audits need reasonable notice, and will be limited in scope and confidential.

12. Liability and order of precedence

Liability under this agreement follows the Terms. If this agreement and the Terms conflict on data protection, this agreement wins.

Annex 1: Processing details

Subject matterHosting and running Customer's agents, workflows, chats, files and connections.
DurationWhile the Workspace exists, plus the 30-day deletion period and backup life.
Nature and purposeStoring, indexing, encrypting, transmitting and otherwise processing data on Customer's instructions, including sending it to the Model Providers and Connected Services Customer chose.
Data subjectsCustomer's staff and users, and anyone whose data Customer puts into the Service, such as its customers, suppliers and job applicants.
Personal dataWhatever Customer provides. Typically names, contact details, messages, documents, phone numbers on WhatsApp channels, and sign-in data for users.
Special categoriesNot intended. Customer must not add them unless it has a lawful basis and suitable safeguards.
FrequencyContinuous while the Service is used.

Annex 2: Security measures

These describe the current product. The security overview has the detail and the known limits.

Annex 3: Subprocessors

See the Subprocessors page.

Signatures

Customer accepts this agreement by using the Service.