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Conduct AI Data Protection Agreement.pdf
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Version: 1.1 Effective Date: March 17, 2026
This Data Processing Agreement ("DPA") is incorporated into and forms part of the Agreement between Conduct AI and the Customer. It establishes the rights and obligations of the Parties with respect to the processing of personal data by Conduct AI on behalf of Customer in connection with the provision of the Services.
In this Annex, the following terms have the meanings set out below. Capitalised terms not defined in this DPA have the meanings given in the ToS.
1.1 "Controller" means the entity which determines the purposes and means of the processing of personal data.
1.2 "Customer Personal Data" means any personal data contained within Customer Data that Customer or its Authorised Users upload, connect, or transmit to the Platform for processing, as further described in Annex I.
1.3 "Data Incident" means any breach of Conduct AI's security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or unauthorised access to, Customer Personal Data processed by Conduct AI.
1.4 "Data Protection Laws" means all applicable laws and regulations regarding data protection and privacy, including without limitation the UK GDPR, the EU GDPR, and the UK Data Protection Act 2018, in each case as amended or replaced from time to time.
1.5 "Data Subject" means the identified or identifiable natural person to whom Customer Personal Data relates.
1.6 "EU GDPR" means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.
1.7 "EU SCCs" means the standard contractual clauses for transfers of personal data from the EEA approved by the European Commission under Commission Implementing Decision (EU) 2021/914, available at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj, as may be replaced or updated from time to time.
1.8 "Personal Data" has the meaning given under applicable Data Protection Laws and includes any information relating to an identified or identifiable natural person.
1.9 "Processing" means any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, storage, use, disclosure, or deletion. The terms "process" and "processed" shall be construed accordingly.
1.10 "Processor" means the entity which processes personal data on behalf of the Controller.
1.11 "Special Category Data" means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a person's sex life or sexual orientation.
1.12 "Sub-Processor" means any third party engaged by Conduct AI to process Customer Personal Data in connection with the provision of the Services.