Data Processing Agreement

Version: 2026-09-27.

1. Parties and roles

2. Subject matter and duration

AtlyChat processes Customer personal data on the Customer's instructions to provide conversations, voice, images, video, files, memory, assistants, projects, groups, the workbench, connected mail, calendar and Drive, the optional Atly Office connection, and the inference API. Processing continues for the term of the service relationship and for a reasonable closure window after termination or an account-deletion request, unless a longer period is required by law.

3. Nature and purpose of processing

Nature: infrastructure operation, storage, retrieval, analysis, transcription, summarisation, drafting, image and video generation, logging, and transmission to the sub-processors listed below as needed to run the product.

Purpose: deliver AtlyChat on the Customer's instructions. AtlyTech does not train or fine-tune foundation models on Customer content.

4. Types of personal data

Depending on what the Customer uses, processing may include:

AtlyChat does not seek special categories of data. The Customer must not intentionally submit special-category data unless the Customer has a lawful basis and instructs AtlyTech accordingly.

Sending mail, creating a calendar event, and changing Drive run only after the Customer confirms in the chat.

5. Categories of data subjects

6. Customer instructions

AtlyTech processes personal data only on documented Customer instructions: use of the product, connected integrations, confirmation of a write in the thread, and written instructions (including support requests). AtlyTech informs the Customer if an instruction appears to infringe the GDPR and may refuse an unlawful instruction.

7. Confidentiality

Persons authorised to process personal data are bound by confidentiality obligations (contractual and/or statutory).

8. Security measures (summary)

Technical and organisational measures include, as implemented in the product:

9. Sub-processors

The Customer authorises AtlyTech to use the following sub-processors, as configured for the service:

AtlyTech informs Customers of a material sub-processor change by a product notice or a documentation update, with reasonable advance notice where feasible. Continued use after that notice is acceptance.

10. International transfers

Where a sub-processor processes data outside the EEA, the transfer relies on that provider's transfer mechanism (for example standard contractual clauses or an adequacy decision) as stated in that provider's terms. The Customer should review those terms for the Customer's region.

11. Assistance to the controller

Taking into account the nature of the processing, AtlyTech assists the Customer with:

12. Retention, return, and deletion

13. Audits

On a reasonable written request, and no more than once a year unless a breach investigation requires otherwise, AtlyTech makes available the information needed to demonstrate compliance with Article 28 (this DPA and a security summary). An on-site audit needs agreement on scope, timing, and confidentiality. The Customer bears the external auditor's cost unless a material breach by AtlyTech is confirmed.

14. AI annex

15. Liability

Liability under this DPA follows the Terms.

Public page: /legal/dpa. Related: /legal/privacy, /legal/terms, /legal/cookies.

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