Policies

1. Roles and scope

For personal data in the documents, questions and account information you submit (“Customer Data”), you are the controller and ClientSafeAI is your processor. This covers the Private AI Workspace and Document Processing. The data may concern your clients, their counterparties, your staff, or anyone else named in your documents, and can include any category of data those documents contain.

2. Processing only on your instructions

We process Customer Data only to provide the Services under the Terms and your documented instructions, which include using the Services' features. We will tell you if we believe an instruction breaks data protection law. We never use Customer Data to train, fine-tune or evaluate any model, never sell it, and never use it for advertising.

3. Confidentiality

Anyone at ClientSafeAI who can access Customer Data is bound by confidentiality and accesses it only as needed to run the Services or to help you when you ask.

4. Security measures

• Encryption in transit for all traffic, from your browser to our origin servers.
• Each Workspace's AI model runs on a GPU server dedicated to that workspace. No third-party AI, OCR or speech-to-text service receives Customer Data. Recordings are transcribed on the workspace's own dedicated GPU server.
• Workspace data is separated per workspace at the application level.
• Passwords are stored as bcrypt hashes. Sessions use an HttpOnly cookie. Requests are rate-limited.
• Document Processing files, extracted text, contact emails and file names are deleted automatically on the schedule in section 8. Workspace recordings are deleted as soon as they are transcribed.
• Each Workspace runs on its own dedicated server, with its own database and files, and shares no storage, database or AI model with any other customer. Its data disk is encrypted at rest.
• Each Workspace is backed up every night. Backups are encrypted on the Workspace's server before a copy leaves it, and the off-site copy is stored with Backblaze in the United States, or with storage you provide.
• Our own database, which holds account, billing and Document Processing records but no Workspace content, is backed up every night. Backups are encrypted, stored in Finland, and used only to restore the Services after a failure.
• Administrative access to production systems is limited to the people who run it.

5. Subprocessors

You authorize us to use these subprocessors:

PostHog (EU) provides cookieless analytics on the marketing website only and receives no Customer Data. We bind each subprocessor to data protection terms at least as protective as this DPA, and we remain responsible for them. We will email Workspace owners at least 30 days before adding or replacing a subprocessor. If you object on reasonable data protection grounds and we can't resolve it, you may cancel and we will refund any prepaid fees for the period after the change.

6. International transfers

Workspace Customer Data is stored and processed on that workspace's dedicated server in the United States, and its encrypted backups are stored in the United States. Document Processing data is stored and processed in the EU. ClientSafeAI is run from the United States, so administration and support access also happen from there. Where either is a transfer out of the EEA, UK or Switzerland, it is made under the European Commission's Standard Contractual Clauses (or the UK and Swiss equivalents), which we will sign with you on request.

7. Helping you meet your obligations

We will help you respond to requests from individuals exercising their data protection rights, and with data protection impact assessments and consultations with regulators, to the extent they concern our processing. If an individual contacts us directly about Customer Data, we will pass the request to you.

8. Deletion and return

• Document Processing: the file, extracted text, contact email and file name are deleted automatically about five minutes after the result is delivered, or 48 hours after the last activity if the job is never paid or fails.
• Workspace: on request, we will export your documents to you within 30 days, and delete all Customer Data in the workspace within 30 days. Data is kept after cancellation until you ask for deletion, so a workspace can be resumed. Call and meeting recordings are the exception: the audio is deleted as soon as it is transcribed, and only the transcript is kept.
• Backups: deleted data remains in encrypted database backups until they roll off, within six months. We restore a backup only to recover the Services, and re-apply any deletions made since it was taken.

9. Personal data breaches

If we become aware of a breach affecting Customer Data, we will notify you without undue delay, and within 72 hours, with the information we have about what happened, the data involved, and what we are doing about it.

10. Audits

We will provide the information reasonably needed to show we comply with this DPA, including answering a reasonable security questionnaire once a year. Any on-site audit needs 30 days' notice, is at your cost, and must be limited to what that information can't show.

11. Precedence

This DPA lasts as long as we process Customer Data for you. If it conflicts with the Terms on data protection, this DPA wins.