Data processing agreement

This agreement (DPA) covers the dataset you upload to pAud AI Lite. It meets Article 28 of the EU General Data Protection Regulation (GDPR). You accept it on the intake form.

1. Parties and roles

• You, the operator who uploads the dataset, are the controller.
• pAud Ltd, a company registered in England and Wales (company number 17241933), registered office 45 Silverstream House, Fitzroy Street, London W1T 6EB, United Kingdom, contact [email protected], is the processor.

2. What we process

• Subject matter and purpose: checking, converting and analysing your raw exports or event log in a private pAud for the free trial.
• Data: whatever your file holds, typically events, timestamps, object ids and attributes. You confirm it holds no special-category data and that personal data is pseudonymised or minimised.
• People: whoever your data describes, for example your staff, customers or suppliers.
• Duration: from upload until deletion, no later than 14 days after your latest upload.

3. Your instructions

We process the dataset only on your documented instructions. This DPA, the trial terms and the choices you make in pAud (such as editing your pack or pressing delete) are those instructions. If EU or member state law requires other processing, we tell you first, unless that law forbids it. If we think an instruction breaks data protection law, we tell you.

4. Confidentiality

Only people who need access to run the service can reach your data. Each of them is bound to confidentiality. Every operations access is written to an audit log.

5. Security measures

• Verified access. Uploads need an email verified by a one-time code. Codes are stored only as a keyed hash, expire after 10 minutes and allow 5 attempts. Your pAud is reached the same way, and a session only opens your own pAud.
• Upload path. Files go straight to private Cloudflare R2 storage with EU jurisdiction, with versioning off. The size and a checksum are verified; a file that fails is deleted. Your file name is stored only as a hash.
• Least privilege. The upload service can only write and the processing worker can only read and delete, each with its own credentials.
• Isolation. Your file is processed in a container with no network, except one allowed connection to Anthropic's API for model-assisted mapping. Your pAud runs in its own container, as a non-root user, with a read-only system and outbound network blocked.
• Encryption. Your pAud's data sits on its own encrypted volume. The key is unique to your submission and is held on a separate server, never stored next to the data. Deleting the key makes any leftover copy of the volume unreadable. All traffic uses HTTPS.
• No extra copies. No backups or snapshots of your data. Crash dumps are off, swap is off or encrypted, temporary files stay inside the encrypted space, and our CDN does not cache your pages or log request bodies.
• Logs and email. Logs hold no request bodies and no file names in clear, and are kept 14 days at most. Emails never contain data values from your files; the report email names your tables and columns.
• People and tools. Your data never goes to laptops, chat or issue trackers. All inspection happens on our servers.
• Model-assisted mapping. To propose how your tables fit together, only their structure (table and column names, types, counts) and up to five sample values per column, with personal-looking values masked, go to Anthropic's API. A person reviews every proposed mapping. Nothing else from your data goes to an AI service.
• Automatic deletion. A sweeper deletes your data 13 days after your latest upload. As a backstop, storage expires uploaded files after 12 days.

6. Sub-processors

You authorise the sub-processors on our sub-processors page, including Anthropic for model-assisted mapping on your tables' structure and masked sample values, reviewed by a person. Each is bound by data protection terms as Article 28(4) GDPR requires. Before we add or replace one, we email you 14 days in advance. You may object; if we cannot meet the objection, you can end the trial and we delete your data at once.

7. Helping you meet your duties

• Requests from people in your data. If someone asks us about their data in your dataset, we pass the request to you without delay and do not answer it ourselves. We help you answer it, for example by deleting the dataset or finding records.
• Security, impact assessments, authorities. We give you the information we have about our processing when you need it for these.

8. Personal data breaches

If we become aware of a breach affecting your data, we tell you without undue delay and within 48 hours. We say what happened, what data and how many records may be involved, the likely consequences, and what we are doing about it. We add details as we learn them.

9. Deletion at the end of the service

At the end of the trial, or earlier when you use the delete link or ask us by email, we delete your dataset and everything derived from it. We send you a deletion receipt that lists what was deleted and when, and states that no backups or snapshots exist. The receipt is our evidence of deletion. We keep no copy unless the law requires it.

10. Audits

On request we give you the information needed to show we meet this DPA, including the relevant audit log entries and your deletion receipt. We allow and contribute to audits, including inspections, by you or an auditor you appoint, on reasonable notice. Write to [email protected].

11. Term and law

This DPA lasts as long as we hold your dataset. Where it conflicts with the trial terms, this DPA wins. Governing law and jurisdiction: the laws of England and Wales, and the courts of England and Wales. Mandatory consumer and data protection rights you have under the law of your own country are unaffected.