DRAFT — v1.1. Structural draft from the platform's legal package. Not legal advice; must be finalized by counsel before commercial use.
For visitor chat data (transcripts, names, emails, IP addresses, approximate location, technical metadata), the Customer is the controller/business and the platform is the processor/service provider. The Customer's configuration of its assistant constitutes its documented processing instructions. Data subjects are the Customer's website visitors.
The platform does not sell personal information, does not share it for cross-context behavioral advertising, and does not retain, use, or disclose it outside providing the Service. The platform does not use Customer content or visitor conversations to train AI models.
Tenant isolation enforced with database row-level security; encryption in transit; access controls with MFA; append-only, hash-chained audit logging; isolated file parsing and upload scanning; rate-limited authentication. Platform staff do not read tenant conversations in normal operation; any break-glass access is time-boxed, logged, and visible to the Customer in its audit log.
General authorization with the published subprocessor list; the platform gives at least 30 days' notice of additions and remains liable for subprocessors' performance.
The platform provides self-service tools for data-subject requests (search by email, export, deletion), and assists with security reviews and impact assessments through its documentation.
The platform notifies the Customer of a personal-data breach affecting its data without undue delay after becoming aware of it. [Counsel: a fixed 24–48h window may be committed once the monitoring and incident-response process (RUNBOOK) has been exercised.]
During the term the Customer can delete conversations, leads, documents, or all data self-service. On termination, data is deleted within 30–90 days, including document chunks of all generations, embeddings, and object storage; backups are purged on the documented backup cycle. Copies held by subprocessors (AI provider API retention, email provider logs) are governed by the subprocessor agreements and are listed in the subprocessor page.
Reasonable audit rights, satisfied initially by documentation and questionnaire responses. [Counsel: SOC 2 language once available; international transfer terms (SCCs) per the chosen GDPR posture.]