1. What the DPA is
Our DPA is an addendum to your subscription agreement. It does not change pricing or functionality; it formalises the data-protection commitments we make as your data processor (or sub-processor, where you are processing third-party data inside our platform). Standard Contractual Clauses (SCCs) are appended where international transfers apply.
2. Who needs one
- You handle personal data of EU, UK, or Swiss residents → DPA + SCCs.
- You handle personal data of California residents → DPA covers the CCPA service-provider obligations.
- You answer to a security/privacy review during procurement → DPA is usually required.
- You are an enterprise customer with internal data-protection policy → DPA on file is best practice.
If your data is purely your own business operational metrics (e.g., AWS cost data with no personal data), a DPA isn’t strictly required, but we can still execute one if your procurement team prefers it.
3. What our DPA covers
- Roles. You are the data controller; AI2BI Hub (CostTrail Inc.) is the data processor for Customer Data, sub-processor for end-user data passing through your tenant.
- Processing scope. Limited to what is needed to deliver the Service. We never process your data for our own marketing, profiling, or model training.
- Sub-processors. Listed at /legal/subprocessors. You receive 30 days advance notice of changes and may object on reasonable grounds.
- International transfers. EU Standard Contractual Clauses (Module 2: controller-to-processor) appended for transfers from the EEA / UK / Switzerland to the US. UK addendum included where applicable.
- Security. Technical and organisational measures: encryption at rest (AES-256, AWS KMS), TLS 1.2+ in transit, access controls, audit logging, incident response. Full list at /legal/data-handling.
- Data subject rights. We assist you in fulfilling GDPR/CCPA access, deletion, correction, and portability requests within 30 days.
- Breach notification. We notify you within 72 hours of confirming a Personal Data Breach affecting your data, consistent with GDPR Article 33.
- Data deletion. On termination or written request, we delete or return Customer Data within 90 days, except where applicable law requires retention.
- Audits. Right to audit our compliance once per year (or more often after a Security Incident), via a mutually agreed independent auditor or by accepting our most recent SOC 2 / similar report.
4. How to request a signed DPA
Email legal@ai2bihub.com with the subject “DPA request” and include:
- Your company’s legal name and address
- Signatory name and title
- Whether SCCs (Module 2 / 3) and / or the UK addendum are needed
- Any in-house DPA template you’d like us to review (we typically agree on our standard template, but we’ll review redlines)
Typical turnaround: 1–3 business days for our standard template, 1–2 weeks for material redlines. Counter-signed copies are countersigned via DocuSign.
