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Data Processing Agreement

Last Updated: October 19, 2026

This Data Processing Agreement ("DPA") forms part of the Terms of Service ("Agreement") between the entity identified as the customer ("Controller", "you") and PartnerAPI ("Processor", "we", "us"), and governs the processing of personal data by PartnerAPI on your behalf.

This DPA is entered into pursuant to Article 28 of the General Data Protection Regulation (EU) 2016/679 ("GDPR") and, where applicable, the UK GDPR.


1. Definitions

  • "Personal Data" means any information relating to an identified or identifiable natural person, as defined in Article 4(1) GDPR.
  • "Processing" has the meaning given in Article 4(2) GDPR.
  • "Data Subject" means the identified or identifiable natural person to whom Personal Data relates.
  • "Subprocessor" means any third party engaged by the Processor to process Personal Data on behalf of the Controller.
  • "Security Incident" means any accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data.
  • "Services" means the services provided by PartnerAPI under the Agreement.
  • "Standard Contractual Clauses" ("SCCs") means the standard contractual clauses for the transfer of personal data to third countries adopted by the European Commission (Decision 2021/914).

2. Scope and Roles

2.1. You are the Controller and PartnerAPI is the Processor with respect to Personal Data processed in connection with the Services.

2.2. This DPA applies to all Personal Data that the Processor processes on behalf of the Controller under the Agreement.

2.3. The duration of processing is the term of the Agreement, plus any post-termination period required for deletion or return of Personal Data as described in Section 12.


3. Subject Matter, Nature, and Purpose of Processing

3.1. The Processor processes Personal Data solely to provide the Services under the Agreement. Processing activities include:

  • Log ingestion and storage — receiving, sanitising, and storing API logs submitted by the Controller's partners for troubleshooting, monitoring, and analytics.
  • Document processing and AI embedding — chunking, generating vector embeddings of, and storing documents uploaded by the Controller to enable AI-powered knowledge retrieval.
  • AI agent conversations — processing user queries via large language models to provide automated partner support.
  • User account management — creating, authenticating, and maintaining user accounts for the Controller's team members and partners.
  • Form collection — collecting and storing responses to Controller-defined forms as part of partner workflows.
  • Workflow and enrolment tracking — recording partner progress through Controller-defined onboarding and lifecycle stages.
  • Campaign delivery and analytics — delivering Controller-defined campaign content to partners and recording interactions.
  • Billing — processing subscription and payment information via Stripe on the Controller's behalf.
  • Transactional email — sending system notifications, invitations, and confirmations.
  • Audit logging — recording platform actions for security, compliance, and abuse detection.

4. Types of Personal Data Processed

The following categories of Personal Data may be processed depending on the Controller's use of the Services:

CategoryExamples
Identity dataNames, email addresses, profile images
Contact dataEmail addresses, phone numbers
Authentication dataOAuth provider identifiers, session tokens
Legal profile dataLegal name, date of birth, consent records
Log dataIP addresses, HTTP request/response metadata (PII sanitised at ingestion)
Document contentContent of documents uploaded by the Controller (may contain Personal Data at the Controller's discretion)
Conversation dataUser messages and AI responses in agent sessions
Form response dataResponses to Controller-defined forms (may contain Personal Data at the Controller's discretion)
Usage and billing dataAPI usage metrics, subscription status, token consumption
Audit dataUser actions, IP addresses, user-agent strings

5. Categories of Data Subjects

  • Tenant administrators — the Controller's team members who manage the platform.
  • Partners — external organisations and their representatives onboarded by the Controller.
  • Partner end users — individuals whose data may appear in API logs or documents submitted by the Controller.

6. Obligations of the Processor

6.1. Documented instructions. The Processor shall process Personal Data only on documented instructions from the Controller, including with respect to transfers of Personal Data to a third country, unless required to do so by EU or Member State law — in which case the Processor shall inform the Controller of that legal requirement before processing, unless prohibited by law.

6.2. Confidentiality. The Processor shall ensure that all persons authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

6.3. Security. The Processor shall implement and maintain appropriate technical and organisational measures as described in Section 7.

6.4. Subprocessors. The Processor shall comply with the conditions for engaging Subprocessors as set out in Section 8.

6.5. Data subject assistance. The Processor shall assist the Controller in fulfilling its obligations to respond to Data Subject requests as set out in Section 10.

6.6. Compliance assistance. The Processor shall assist the Controller in ensuring compliance with its obligations under Articles 32 to 36 GDPR, taking into account the nature of processing and the information available to the Processor.

6.7. Deletion and return. At the end of the provision of Services, the Processor shall delete or return Personal Data as set out in Section 12.

6.8. Audit. The Processor shall make available to the Controller all information necessary to demonstrate compliance with this DPA and allow for and contribute to audits as set out in Section 13.


7. Security Measures (Article 32)

The Processor implements and maintains the following technical and organisational measures to ensure a level of security appropriate to the risk:

Encryption:

  • Personal Data encrypted at rest using AES-256-GCM (API keys, tokens, sensitive fields).
  • All data in transit encrypted via TLS.
  • Object storage (S3) protected by server-side encryption (SSE-S3).

Tenant data isolation:

  • Log storage isolated per tenant via dedicated organisational identifiers (Loki X-Scope-OrgID).
  • Vector embeddings stored in per-tenant collections (ChromaDB).
  • All database queries scoped by tenant foreign key.

PII sanitisation:

  • Automated stripping of email addresses, phone numbers, national identity numbers, and payment card numbers from API logs before storage.

Access control:

  • Role-based access control (RBAC) across all platform features.
  • OAuth-based authentication with database-level session validation.
  • Active sessions invalidated upon account deletion.

Audit logging:

  • Write-only audit trail of all significant platform actions.
  • Logs retained for 7 years, then anonymised (user identifiers and IP addresses removed).

Infrastructure:

  • Primary data storage in the EU (AWS eu-west-1 for the application bucket; AWS eu-north-1 for the customer-log object storage and supporting infrastructure).
  • Regular security assessments and monitoring via Sentry (EU) and Grafana Cloud (EU).

8. Subprocessors

8.1. General authorisation. The Controller provides general written authorisation for the Processor to engage Subprocessors to perform specific processing activities. The current list of Subprocessors is available at partnerapi.com/legal/subprocessors.

8.2. Notification of changes. The Processor shall notify the Controller at least 30 days before adding or replacing a Subprocessor, giving the Controller the opportunity to object. Notification will be sent to the email address associated with the Controller's account.

8.3. Right to object. If the Controller objects to a new Subprocessor on reasonable data protection grounds within the 30-day notice period, the parties shall discuss the concern in good faith. If a resolution cannot be reached, the Controller may terminate the affected Services without penalty.

8.4. Flow-down obligations. The Processor shall impose on each Subprocessor, by way of a written contract, data protection obligations no less protective than those set out in this DPA. The Processor remains fully liable to the Controller for the performance of each Subprocessor's obligations.

8.5. Current Subprocessors:

<!-- SUBPROCESSORS:START (auto-generated from docs/gdpr/subprocessors.yaml — run pnpm subprocessors:generate after editing the YAML) -->
SubprocessorPurposeLocationTransfer Mechanism
AWS (S3, SES)Object storage, email deliveryEU (eu-west-1, eu-north-1)N/A (EU)
RenderManaged application hosting and managed database — runs the PartnerAPI API and its background workers, and hosts the primary application database. Render operates on AWS infrastructure.EU (Frankfurt) — application services, background workers and managed PostgresEU-US DPF + SCCs + DPA
VercelFrontend application hosting — serves the public tenant landing pages and the authenticated partner portal, including sign-in and server-side rendering of portal pages. Personal data passes through Vercel in transit and in server-render memory; the web tier holds no database of its own. Vercel operates on third-party cloud infrastructure.US (Vercel Inc.) — no deployment region pinned in our configurationSCCs + DPA
SentryError tracking and monitoringEUN/A (EU)
Grafana Cloud (Loki)Platform service-log storage and querying — PartnerAPI's own observability only. Customer API logs are not stored here; they live in PartnerAPI's own log infrastructure in AWS eu-north-1.EUSCCs
OpenAIAI embedding generation, inference, and content moderation for partner-uploaded knowledge documentsUSSCCs + DPA
Chroma Inc. (Chroma Cloud)Vector embedding storage for tenant document content (per-tenant collections used for AI knowledge retrieval)EU (GCP europe-west1, Belgium) — Chroma Inc. is US-basedSCCs + DPA (DPA under review)
Vercel (v0)Generative AI for tenant landing pages — when a tenant admin asks for a landing page to be generated or changed, the prompt, any reference-page content and the page's current HTML are sent to Vercel v0 to produce the new page. Personal data reaches it only where the tenant's own prompt or page copy contains it.US (Vercel Inc.)SCCs (pending acceptance) (DPA under review)
Vercel (Sandbox)Isolated, single-use compute for automated dependency upgrades — when a customer enables upgrade runs, a copy of the connected code repository (including commit author names and email addresses in its history) is built and updated inside a temporary virtual machine with restricted network access. Not yet in use; listed in advance.US (Vercel Inc., iad1 region)SCCs + DPA
SlackNotification delivery to your own Slack workspace, and the Slack interface to the assistant. Notification content, assistant conversations held in Slack, and the Slack account identifier used to route them are processed by Slack.USSCCs + EU-US DPF + DPA
Zoom (Zoom Scheduler)Meeting booking for the final step of the partnership-map claim flow — the email address of someone claiming a company profile is passed to Zoom's scheduler so the booking form arrives prefilled, and Zoom records the booking details.USSCCs + EU-US DPF + DPA
MailjetTransactional email deliveryEUN/A (EU)
StripePayment processing and billingUS/EUSCCs + DPA
Atlassian (Confluence + OAuth)OAuth identity provider; Confluence page content ingestion when the Controller enables the Confluence integrationUSSCCs + DPA
<!-- SUBPROCESSORS:END -->

9. International Data Transfers

9.1. The Processor stores Personal Data primarily in the European Union: the primary application database is Render-managed Postgres in Frankfurt, and object storage is AWS eu-west-1 (application data plane) and AWS eu-north-1 (customer-log object storage and Loki/EBS supporting infrastructure). Those locations are within the EU/EEA, so no SCCs are required for intra-EU storage as such. Two things follow that this clause states rather than leaves implicit: storage location is not processing location, so see the Location column in §8.5 for where each Subprocessor processes and §9.2 for processing outside the EU/EEA; and where the provider of an EU-located store is itself established outside the EU/EEA, SCCs remain the controlling Article 44–49 instrument, which is why the Transfer Mechanism column in §8.5 names SCCs for such a Subprocessor even where the data sits in the EU.

9.2. Where Personal Data is transferred to, or processed by, a Subprocessor located outside the EU/EEA, the Processor ensures that such transfers are protected by Standard Contractual Clauses (SCCs) adopted by the European Commission (Decision 2021/914), supplemented by additional technical measures where necessary. The Location column in §8.5 above identifies each Subprocessor's processing location and the Transfer Mechanism column names the instrument relied on, including where a data processing agreement is still under review; §8.5 rather than this clause is the current list, so that the two cannot drift apart.

9.3. The Processor shall inform the Controller if it becomes aware that an international transfer cannot be completed in compliance with applicable data protection law, and shall work with the Controller to identify an alternative solution.


10. Data Subject Rights

10.1. Taking into account the nature of the processing, the Processor shall assist the Controller by appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of the Controller's obligation to respond to requests for exercising Data Subject rights under Chapter III GDPR, including:

  • Right of access (Article 15)
  • Right to rectification (Article 16)
  • Right to erasure (Article 17)
  • Right to restriction of processing (Article 18)
  • Right to data portability (Article 20)
  • Right to object (Article 21)

10.2. The Processor provides automated tools to support the Controller in responding to Data Subject requests, including data export (machine-readable JSON), account deletion, profile rectification, processing restriction, and AI data-processing opt-out.

10.3. If the Processor receives a Data Subject request directly, it shall promptly redirect the request to the Controller, unless otherwise instructed.

10.4. The Processor shall respond to Controller requests for assistance within 10 business days, or sooner where required to meet the Controller's regulatory deadlines.


11. Security Incident Notification

11.1. The Processor shall notify the Controller without undue delay and no later than 48 hours after becoming aware of a Security Incident affecting the Controller's Personal Data.

11.2. The notification shall include, to the extent available:

  • A description of the nature of the Security Incident, including the categories and approximate number of Data Subjects and records affected.
  • The name and contact details of the Processor's Data Protection Officer.
  • A description of the likely consequences of the Security Incident.
  • A description of the measures taken or proposed to address the Security Incident, including measures to mitigate its possible adverse effects.

11.3. Where it is not possible to provide all information at the same time, the Processor shall provide information in phases without further undue delay.

11.4. The Processor shall co-operate with the Controller and take reasonable steps to assist in the investigation, mitigation, and remediation of the Security Incident.

11.5. Notification of a Security Incident shall not be construed as an acknowledgement of fault or liability by the Processor.


12. Data Deletion and Return

12.1. Upon termination or expiry of the Agreement, and upon the Controller's written request, the Processor shall either:

  • (a) return all Personal Data to the Controller in a structured, commonly used, and machine-readable format; or
  • (b) delete all Personal Data, including all copies, from the Processor's systems and those of its Subprocessors.

12.2. The Processor shall complete deletion or return within 30 days of receiving the Controller's written instructions, unless EU or Member State law requires further storage.

12.3. Where retention is legally required, the Processor shall inform the Controller of the requirement and limit processing to that which is required by law.

12.4. The Processor shall certify deletion in writing upon the Controller's request.


13. Audit Rights

13.1. The Processor shall make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in Article 28 GDPR and this DPA.

13.2. The Processor shall allow for and contribute to audits, including inspections, conducted by the Controller or an independent auditor mandated by the Controller, subject to the following conditions:

  • (a) The Controller shall provide at least 30 days' prior written notice of an audit.
  • (b) Audits shall be conducted during normal business hours, no more than once per calendar year, unless a Security Incident or regulatory requirement necessitates an additional audit.
  • (c) The Controller shall ensure that auditors are bound by confidentiality obligations.
  • (d) The audit scope shall be limited to the Processor's processing of the Controller's Personal Data.

13.3. If the same audit information has been provided to the Controller within the previous 12 months via a third-party audit report (e.g., SOC 2), the Processor may make that report available in lieu of a further audit, provided it reasonably addresses the Controller's concerns.


14. Data Protection Officer

The Processor has appointed a Data Protection Officer who can be contacted at:

  • Email: dpo@partnerapi.com
  • General legal enquiries: legal@partnerapi.com

15. Liability

Each party's liability under this DPA shall be subject to the limitations and exclusions of liability set out in the Agreement. Nothing in this DPA limits either party's liability for breaches of its data protection obligations where such limitation is not permitted by applicable law.


16. Term and Amendments

16.1. This DPA shall remain in effect for the duration of the Agreement and for as long as the Processor processes Personal Data on behalf of the Controller.

16.2. The Processor may update this DPA from time to time to reflect changes in applicable law or the Services. Material changes will be notified to the Controller at least 30 days in advance. Continued use of the Services after the effective date of changes constitutes acceptance of the updated DPA.


17. Governing Law

This DPA shall be governed by and construed in accordance with the laws that govern the Agreement, unless otherwise required by mandatory data protection law.


18. Contact

For questions about this DPA or our data protection practices:

  • Data Protection Officer: dpo@partnerapi.com
  • Legal & Compliance: legal@partnerapi.com
  • Security incidents: security@partnerapi.com

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