Data processing agreement

# Data processing agreement *Version 2. It replaces version 1, whose bracketed placeholders it resolves. It has not yet been reviewed by a lawyer.* This agreement covers what we may and may not do with the personal data you give us while running your agents. It forms part of your contract with us. **Between** - **You**, the customer named on the workspace ("you"). You decide what data goes into ZenOS and why. In data-protection law you are the *controller*. - **The provider of ZenOS identified on the Legal notice at https://zen-os.net/imprint** ("we", "us"). We process that data on your behalf. In data-protection law we are the *processor*. Where this agreement says "data protection law", it means the UK General Data Protection Regulation and the Data Protection Act 2018, and the EU General Data Protection Regulation, whichever apply to you. --- ## 1. What we process, and for how long We process the personal data described in **Schedule 1**, for as long as your subscription lasts, plus the retention periods in **Schedule 5**. ## 2. We act only on your instructions We process your personal data only to provide the service, and only on your instructions. Your instructions are the ones you give through the product itself: the agents you switch on, the instructions you publish to them, the documents you upload, and the approvals you give. We do not process your data for our own purposes. **We do not use your data to train any artificial-intelligence model, and neither does the provider that runs the models for us.** If we ever believe an instruction from you would break data protection law, we will tell you and will not act on it until it is resolved. ## 3. Confidentiality Everyone we allow to access your personal data is bound by a duty of confidentiality, whether as an employee or under contract. ## 4. Security We keep your personal data secure using the measures in **Schedule 3**. Those measures are technical facts about how the product is built, not intentions. If we change them, we will not weaken the overall level of protection. ## 5. Other companies that help us (sub-processors) **Schedule 4** lists every company that processes your personal data on our behalf, what each one does, and where it processes. You agree to our using the companies listed there. If we want to add or replace one, we will give you 30 days' advance notice by email to the workspace owner and on https://zen-os.net/sub-processors. If you object on reasonable data-protection grounds within that period, you may end the affected part of the service without penalty. We remain responsible to you for what these companies do with your data, and we put obligations on them that are equivalent to the ones in this agreement. **Schedule 4 records, honestly and per company, whether that written agreement is currently in place.** Where it is not, that is stated plainly rather than implied. ## 6. Helping you when someone exercises their rights If someone asks you for a copy of their data, asks you to correct it, or asks you to delete it, we will help you respond. The product includes an erasure tool you can use yourself. It removes personal data while leaving our record of decisions verifiable, so we can still show that the record was not altered afterwards. If someone contacts us directly about data you control, we will not respond to them ourselves beyond acknowledging receipt. We will pass it to you. ## 7. Helping you with security incidents and assessments If we become aware of a personal data breach affecting your data, we will tell you without undue delay and in any event within 24 hours of becoming aware of it. We will tell you what we know, what we are doing about it, and what we recommend you do. We will also help you with data protection impact assessments and any prior consultation with a regulator, by giving you the information we hold about how the processing works. ## 8. Getting your data back, and deletion An export of your workspace's data is produced when your workspace is cancelled, as part of offboarding. You can also ask for an export at any other time by writing to us, and we will produce one. When your subscription ends, we delete your personal data on the timetable in **Schedule 5**, unless the law requires us to keep it. If you ask us in writing before then, we will return it to you first. ## 9. Showing you we comply We will give you the information you reasonably need to show that we are meeting our obligations under this agreement, and we will allow and contribute to audits. On written request, we will answer with the evidence the service records: the audit record for your workspace, the sub-processor list, and our security documentation. On-site audits are available by separate agreement, at your cost, and no more than once a year unless a supervisory authority requires otherwise. ## 10. Sending data outside the UK and the European Economic Area Your workspace data is stored in a named region in **Frankfurt, Germany** — deliberately a specific German region, not a general "Europe" grouping, which can place data in London or Zurich. Some of the companies in Schedule 4 process data outside the European Economic Area. Where that is the case, the transfer relies on the EU–US Data Privacy Framework where that company is certified, and otherwise on the European Commission's standard contractual clauses. The sub-processor list shows, per company, whether its agreement and clauses are recorded as signed yet. ## 11. Liability Each party's liability under this agreement is as set out in the Terms of service at https://zen-os.net/terms. ## 12. How long this lasts This agreement lasts as long as we process personal data for you. Clauses that by their nature should survive — confidentiality, deletion, liability — continue afterwards. ## 13. Law and jurisdiction The law of the Republic of Slovenia applies, and the courts of Ljubljana have jurisdiction, unless mandatory law says otherwise. --- # Schedule 1 — What we process **Why.** To run AI agents against your own business data and produce internal reports for you. **What the agents do.** Every available agent reads only what you upload and writes an internal report. **No agent sends email, publishes to social accounts, issues invoices, or changes advertising campaigns.** Those capabilities exist in the product but are switched off and refuse. The agents available are: client status reporting; delivery risk; client health; proposal and estimate drafting. **Types of personal data.** Whatever you choose to upload. In practice this is likely to include names and contact details of your own staff and your clients' staff, project notes, time records and commercial correspondence. **You must not upload** special-category data (such as health, ethnicity, religion, biometrics or sexual orientation) or data about criminal offences. The product has no specific safeguards for these categories. **Whose data.** Your employees and contractors, and the employees and contacts of your own clients. **How long.** The term of your subscription, plus Schedule 5. # Schedule 2 — Your instructions Your documented instructions are the configuration you set in the product: - which agents you enable, and at what level of autonomy - the instructions you publish to each agent, each recorded with a version - the documents you upload as knowledge - the approvals and rejections you give Every agent run records the exact instruction version and the exact pieces of your knowledge that produced its output, so what we acted on is always recoverable. # Schedule 3 — Security measures - **Where your data lives.** A named region in Frankfurt, Germany. - **Separation between customers.** Enforced by the database itself, not by application code. A test that deliberately attempts to read another customer's data, and must fail, runs before every release. - **Least privilege.** The website, the background worker and the administrative connection are three separate database identities. The administrative one, which can change the structure of the database, is used only for upgrades and is never given to a running application. - **No agent ever holds a working key.** An AI model cannot call anything that changes the world. It writes a proposal; ordinary, deterministic code decides whether that proposal happens. - **Untrusted content is contained.** If a run reads anything originating outside your company, it immediately loses the ability to reach any tool that acts outside your company, for the rest of that run. This is enforced in two independent places. - **A record that cannot be quietly rewritten.** Every decision is written in the same database transaction as the change it describes, and the records are linked by cryptographic hash. The chain still verifies after an erasure, so we can show the history was not altered. - **Credentials.** Keys for connected services are stored as pointers, never as values in our database, and never appear in a log, an error message or a stack trace. - **Access.** Two-factor authentication is supported, and re-authentication is required before the highest-risk actions. # Schedule 4 — Companies that process your data for us The current list, with each company's purpose, processing region and whether its agreement and clauses are signed, is published at https://zen-os.net/sub-processors and is generated from the same records the service runs on. # Schedule 5 — Keeping and deleting data The full text of what an agent read and produced is kept for: | Your plan | Kept for | | --- | --- | | Free | 7 days | | Bring your own key | 90 days | | Pro | 90 days | | Max | 180 days | | Ultra | 365 days | The record of *decisions* — who approved what, when, and on what basis — is kept longer than the full text. That record is what lets you audit your own agents, and it holds no document contents. After you cancel, the company that stores your workspace data deletes it within 30 days. --- **Version 2. Effective 2026-09-26.**