Data processing agreement
Draft document — to be reviewed by a lawyer.
When your organisation sends traces to WYRLO, it remains the controller and WYRLO acts as a processor. Article 28 of the GDPR requires a contract between the two. Here is what it covers.
What the agreement covers
In line with article 28 of the GDPR, the agreement sets out:
- processing only on your documented instructions;
- confidentiality obligations for the people authorised to process the data;
- the security measures in place;
- the conditions for engaging sub-processors;
- help with responding to requests to exercise data subject rights;
- assistance in the event of a data breach and with impact assessments;
- deletion or return of the data at the end of the agreement;
- the information made available to demonstrate compliance, including audits.
Subject matter of the processing
- Nature: checking your RAG’s answers, computing the confidence level, adjusting settings every night and producing the weekly report.
- Data: questions, passage excerpts and answers (the traces), masked before storage; account data for your organisation.
- Data subjects: users of your RAG and members of your organisation [categories TO BE CONFIRMED].
- Your documents are never stored.
Duration
The agreement applies for as long as you use the service.
Traces are kept for 30 days by default, then deleted; your organisation can choose 30, 90 or 180 days. [Time limit for deleting data at the end of the agreement: TO BE CONFIRMED]
Security measures
- hosting in the European Union (Paris);
- masking of traces before storage;
- strict isolation between organisations, enforced by access rules at database level;
- API keys stored only as a hashed fingerprint;
- activity log of sensitive actions;
- encryption [scope TO BE CONFIRMED].
These measures are described in detail on the Security page.
Sub-processors
- Supabase: database and functions, eu-west-3 region (Paris). Address: [TO BE CONFIRMED]
- Vercel: web application hosting, functions in the cdg1 region (Paris). Address: [TO BE CONFIRMED]
[Full list, prior notice of changes and right to object: TO BE CONFIRMED]
Getting the agreement
The agreement is sent on request [address TO BE CONFIRMED].