Data Processing Addendum

Annex B. Data Processing Addendum

This DPA is part of the Terms. It applies when we process Personal Information in your Content on your behalf.

It applies to you automatically, with no signature, if you use the Service for a business and your Content holds Personal Information about other people. Every Organization Customer is covered. An Individual Customer is covered when acting for a business. Section 19 (Who is responsible for personal information) explains who is covered. An Individual Customer who uses NATEX Work only for personal purposes is not covered by this DPA. Section 26 (Your privacy rights) of the Privacy Policy applies to that Customer directly.

The parties are NATEX AI, Inc. (we) and the Customer (you). If this DPA conflicts with another part of the Agreement about how we process Personal Information in Content, this DPA controls. Section B16 (Liability and precedence) sets the limit on liability.

B1 Parties, roles, subject matter

B1.1 For Personal Information in Content, you are the Controller and we are your Processor. The word Processor includes a "service provider" or "contractor" under US state privacy laws, and we are one for Content.

B1.2 For Account Data, billing, security, abuse, support and product-operations data, we are the Controller. Section 2 (Our two roles) of the Privacy Policy describes that use. This DPA does not apply to it.

B1.3 You decide what Content to put into NATEX Work and why. You are responsible for the lawful basis for it and for the notices to the people it concerns (Section B15 (Customer duties)).

B1.4 The subject matter is the Service we provide to you. The nature of the processing is storing, syncing, searching, displaying, transmitting, backing up and deleting your Content. It also includes sending text from your Content to AI Features and to Connected Services at your direction, and sending the messages you ask us to send. The purposes are the business purposes in Section B3 (Service provider terms under US state privacy law). The duration is the time we hold your Content, which is the term of the Agreement plus the periods in Section B9 (Return and deletion).

B1.5 The types of Personal Information and the people it concerns are in Annex B-1 at the end of this DPA.

B2 Instructions

B2.1 We process Personal Information in Content only on your documented instructions. Your documented instructions are:

• (a) the Agreement, including this DPA;
• (b) the settings you and your Admins choose in NATEX Work, such as AI exclusions, Local-Only Mode and retention settings;
• (c) your use of the Service, including the API, the MCP Server, Webhooks and every Agent Action under your Account or your Workspace's keys; and
• (d) written instructions you send to nshulman@natex.ai that are consistent with the Agreement.

B2.2 A Third-Party Agent that holds your API Key is a recipient you chose. What you route to it is your instruction. Section 12 (API, MCP Server and Webhooks) says more.

B2.3 If we believe that an instruction breaks the law, we tell you and may stop acting on it until you confirm it or change it.

B2.4 If the law requires us to process Personal Information in Content in another way, we tell you before we do, unless the law forbids us to tell you.

B3 Service provider terms under US state privacy law

B3.1 This section applies to Personal Information in Content that the California Consumer Privacy Act covers. It also applies to the similar laws of other states.

B3.2 You disclose Personal Information to us only for the limited and specified business purposes in this section:

• (a) to host, store, sync, search, display, transmit and delete your Content;
• (b) to process your Content as you direct, through AI Features and Connected Services you use, and to send the messages you ask us to send;
• (c) to back up and recover the Service;
• (d) to keep the Service and your Content secure, and to detect and prevent abuse and fraud;
• (e) to give support that you ask for; and
• (f) to comply with law.

B3.3 We do not "sell" Personal Information in Content. We do not "share" it for cross-context behavioral advertising. These words have the meanings that the California Consumer Privacy Act gives them.

B3.4 We do not retain, use or disclose Personal Information in Content for any purpose other than the business purposes in paragraph B3.2. That includes any commercial purpose of our own. We do not retain, use or disclose it outside our direct business relationship with you.

B3.5 We do not combine Personal Information in Content with Personal Information that we receive from other sources or collect from our own interactions with people, except as the law lets a "service provider" do. This is the statement about our infrastructure:

NATEX Work has its own database and sign-in system, separate from NATEX AI's other products. NATEX AI uses one Stripe account and one OpenRouter account for all of its products. Your NATEX Work data is used only by NATEX Work.

B3.6 We will comply with the obligations that the California Consumer Privacy Act places on a "service provider". We will give Personal Information in Content the same level of privacy protection that the law requires of you as a business.

B3.7 You may take reasonable and appropriate steps to confirm that we use Personal Information in Content in a way that is consistent with your obligations. You may do this at least once every 12 months. Section B10 (Audit and information) explains how.

B3.8 We will tell you without undue delay if we decide that we can no longer meet our obligations under this section or under the law.

B3.9 If you reasonably believe that we are using Personal Information in Content without authorization, you may take reasonable and appropriate steps to stop it and to remediate it. Tell us at nshulman@natex.ai and we will work with you.

B3.10 We help you respond to requests from people about their Personal Information in Content, as Section B8 (Assistance) says.

B3.11 We use each Sub-processor under that Sub-processor's published terms and, where it offers them, its data processing terms. For Model Hosts, which we reach through OpenRouter, the terms we rely on are OpenRouter's terms for Model Hosts. We have no separate contract with an individual Model Host or with Perplexity. We have not signed a data processing agreement with Composio, so we do not represent that Composio is bound by every term of this Section B3. If you cannot accept that for particular data, do not connect a Connected Service that uses Composio. Section B6 (Sub-processors) describes this further.

B3.12 You will tell us about any consumer request that we must act on for Content, and give us the information we need to act on it.

B4 Processor contract terms in other states

B4.1 We limit access to Personal Information in Content to Staff who need it to provide the Service, and each of them is bound by a duty of confidentiality.

B4.2 At your direction, we delete Personal Information in Content or return it to you when the Agreement ends, as Section B9 (Return and deletion) describes.

B4.3 On your reasonable request, we give you the information needed to show that we meet this DPA. Section B10 (Audit and information) explains the limits.

B4.4 We allow a reasonable assessment of our processing once every 12 months, or we give you a report from a qualified independent assessor instead, as Section B10 (Audit and information) describes.

B4.5 We use each Sub-processor under its published terms, as Section B6 (Sub-processors) explains and as Section B3.11 states for Model Hosts, Perplexity and Composio. We pass on the obligations in this DPA to the extent each Sub-processor's published terms allow.

B5 Security measures

B5.1 We use reasonable administrative, technical and physical safeguards for Content. No security is absolute. These are the measures we use. We promise no others.

• (a) Encryption in transit. We use TLS to protect data in transit.
• (b) Encryption at rest by our vendors. Supabase encrypts its disks with AES-256. Cloudflare R2 encrypts stored objects with AES-256-GCM, with keys that Cloudflare manages. This is disk-level encryption. It does not encrypt Content inside the database from someone who has database access.
• (c) Encryption in our application. We encrypt stored mailbox (IMAP) passwords and Webhook secrets with AES-256-GCM in our own code.
• (d) API Keys. We store only a SHA-256 hash of each API Key.
• (e) Workspace isolation. Row-level security separates Workspaces from each other in the database.
• (f) Approval gates. Risky actions need explicit approval. Section 10 (Teammates, Automations and actions taken for you) explains Approvals and Auto-Apply.
• (g) Public Pages. Public Pages use long random tokens.
• (h) Sign-in controls. Two-factor authentication is available. A Workspace may require it.
• (i) Card data. Card data never reaches our servers. Stripe handles it.
• (j) Backups. Each Backup file is encrypted with AES-256-GCM in our own application before it is stored, and our storage vendors also encrypt their disks. We hold the key only as a server secret, kept apart from the Backups, plus one offline copy that our founder keeps. File names inside a Backup show table names.
• (k) Staff access. The next paragraph states our limits on Staff access.

B5.2 Our Staff do not read your Content except to give support you ask for, to investigate security or abuse, or to comply with law. Access through our admin tools is recorded in the Staff Access Log, and your Admins can see the entries for your Workspace. Direct access to our database is limited to named, authorized Staff and is not recorded by the application.

B5.3 You secure your Members' credentials, API Keys, Webhook secrets and Connected Service permissions. Section 21 (Security, confidentiality and shared responsibility) says more. Section 21 (Security) of the Privacy Policy says the same in plain words.

B5.4 We make no promise of any compliance certification. NATEX Work is not a HIPAA, GLBA, FERPA, PCI or FedRAMP environment.

B5.5 Annex B-2 (Security measures) is this section.

B6 Sub-processors

B6.1 You give us a general authorization to use the Sub-processors on the Sub-processor List. The list is in Section 8 (Sub-processor List) of the Privacy Policy. This section does not copy it.

B6.2 This is how we change the list:

We publish the Sub-processor List with each Sub-processor’s legal name, what it does, the data it handles, where it processes that data and the date we added it. We give the Workspace Owner and the Admins an in-app notice in Settings > Privacy at least 30 days before a new Sub-processor starts to process Content. When we do not choose the change ourselves, for example because a Sub-processor changes its own vendors, we give notice as soon as we reasonably can, normally 30 days. If you object within 30 days of the notice, an Admin records the objection in Settings > Privacy with "Object to this Sub-processor". You may then end your plan, and we will refund the unused part of what you prepaid, as Section S1.10 (Refund Policy) of the Plan and Billing Terms describes. We also work with you on any data-protection concern.

B6.3 Section S1.10 (Refund Policy) of Schedule 1 says how we work out and pay a refund under paragraph B6.2, and that you do not need to ask.

B6.4 We use each Sub-processor under that Sub-processor's published terms and, where it offers them, its data processing terms. Paragraph B3.11 of Section B3 (Service provider terms under US state privacy law) says where there is no separate contract. We pass on the protections in this DPA to the extent that those terms allow. The Sub-processor List shows where a Sub-processor acts only under its standard terms. We are responsible for the acts and omissions of our Sub-processors on Content as we are for our own, subject to Section B16 (Liability and precedence).

B6.5 Connected Services need special care. Composio (Sampark, Inc.) and Nango (Nango Inc) are Integration Providers. We use them only when you connect a Connected Service that needs them.

Composio connects many of the apps you add. It can keep the content of tool calls, which can include message text, for up to 1 year, including after you disconnect an app. That is outside our deletion windows.

We have not signed a separate data processing agreement with Composio. Composio's standard terms apply. Nango Inc holds tokens and pasted keys and proxies requests for the Connected Services it serves. If you cannot accept this for particular data, do not connect a Connected Service that uses Composio or Nango for that data.

B6.6 An Independent Recipient is not a Sub-processor. Section 7 (Who receives information) of the Privacy Policy lists them. A Third-Party Agent that holds your API Key is a recipient you chose and is not our Sub-processor (Section 12 (API, MCP Server and Webhooks)).

B7 Security Incident notice

B7.1 If a Security Incident affects your Content, we will tell the Workspace Owner and the Admins without undue delay and no later than 72 hours after we become aware that it happened, and we will include the information you need for your own notices. Nothing here shortens a deadline that the law gives you or imposes on us.

B7.2 To the extent we know it, the notice describes:

• (a) what happened and when;
• (b) the kinds of Content and the approximate number of Workspaces and records affected;
• (c) the likely consequences;
• (d) what we have done and will do to contain the problem and to reduce harm; and
• (e) how to reach us about it, at nshulman@natex.ai.

B7.3 If we do not yet know all of this, we give you what we have and add the rest as we learn it.

B7.4 We cooperate with you in investigating the Security Incident and in preparing your notices to regulators and to the people affected. You decide whether and how to notify your own contacts, subject to your legal duties. Section 21 (Security) of the Privacy Policy says the same in plain words.

B8 Assistance

B8.1 We help you meet your duties to respond to requests from people about their Personal Information in Content. Your Admins already have these tools: Export, the ability to edit and delete records, and the Privacy Center. Section 20 (Export, deletion and retention) lists the paths.

B8.2 If a Non-User asks us for something about Content in your Workspace, we aim to forward the request to the Workspace's Admins within 10 Business Days. A Non-User can also use the form at /legal/privacy-request. You answer it, and we help you do so.

B8.3 We help you with your security duties, your Security Incident notices (Section B7 (Security Incident notice)), and your data-protection impact assessments or risk assessments, by giving you the information about the Service that we have.

B8.4 If your request needs effort beyond the features of the Service and ordinary support, we may charge a reasonable fee based on our actual cost. We tell you the amount before we do the work.

B9 Return and deletion

B9.1 During the term, you can export your Content at any time. A Member can use Settings > Account > Download my data. An Admin can use Settings > Admin > Data > Download workspace ZIP. The Export limits in Section 20 (Export, deletion and retention) apply.

B9.1A When a Member leaves or is removed, we delete that Member's Personal Memory and saved AI keys for the Workspace. Team Memory is deleted when an Admin turns it off and with the Workspace. Team Memory is part of the Workspace ZIP that an Admin downloads. Personal Memory is not; a Member downloads it with Download my data.

B9.2 If we end your access for a reason other than abuse or illegality, you have 30 days after the termination to export your Content. Section 26 (Suspension and termination) applies.

B9.3 At your choice, we delete or return your Content. Return means an Export. The Workspace Owner can delete a Workspace at Settings > Team > Delete this workspace. After the Agreement ends, you can also ask us in writing at nshulman@natex.ai to delete the Workspace. When the 30 days in paragraph B9.2 have passed, we may delete the Workspace without being asked. On request, we confirm the deletion in writing.

B9.4 This is what deletion means:

When you delete something, it leaves the live system at once or after the 30-day Trash Window. Copies in Backups are gone within 60 days. Uploaded files are not in Backups. Copies in the command log expire after 90 days. When you disconnect a Connected Service, we delete what it brought in, after showing you the list. Some information stays where our vendors keep it under their own terms: Composio can keep the content of tool calls for up to 1 year, Brevo keeps delivery logs, Stripe keeps the payment records it must keep, and Supabase and Cloudflare keep platform logs. We keep Acceptance Records, billing consent records and the records of refunds and objections for 7 years as evidence of your agreement and of what we did. The deletion audit row holds counts only, with no name, email or id, for 1,095 days. A Seller’s own Stripe account stays open when a Workspace is deleted.

B9.5 A Backup is a rolling copy of the database that we keep apart from the live database for recovery. We keep 14 daily copies and 8 weekly copies. A Backup holds the names and sizes of uploaded files but not the files. The Backup Roll-Off Period is 60 days. We cannot take Content out of a Backup before the Backup rolls off.

B9.6 We keep records that the law requires us to keep, and the records that the Retention Schedule in Section 23 (Retention Schedule and deletion) of the Privacy Policy lists.

B9.7 Section 22 (Government requests, civil subpoenas and Legal Holds) explains how to ask us to pause our deletion jobs for a named Workspace.

B10 Audit and information

B10.1 We are a small company, and audits must fit that. They must be proportionate to the size of our business and to the risk.

B10.2 Once every 12 months, you can ask us for a written summary of our security measures and for answers to a reasonable security questionnaire. We give you both.

B10.3 If we obtain an independent audit or assessment report that covers the Service, we give you a copy on request, under confidentiality.

B10.4 Once every 12 months, on 30 days' notice, you or an assessor you appoint may assess our processing of your Content by reviewing documents and interviewing our Staff, at your cost, including our reasonable time at our actual cost. Instead, we may give you a report from a qualified independent assessor. The assessment takes place during business hours without disturbing the Service. It does not reach other Customers' data or our vendors' systems. You and your assessor keep what you learn confidential.

B10.5 We cannot give you audit rights over our Sub-processors. Where their terms let us, we share the reports and security information we receive from them.

B11 Transfers

B11.1 NATEX Work is offered only in the Territory. This is the region statement:

Most processing happens in the United States. Some Model Hosts and other Sub-processors may process information elsewhere, and we do not promise that it stays in the United States.

B11.2 You may be a business that serves people located outside the United States. If you need the Standard Contractual Clauses of the European Commission (Modules 2 and 3) or the UK Addendum to them for Personal Information in your Content, ask us at nshulman@natex.ai. We will enter into them with you.

B11.3 If a transfer mechanism that we or a Sub-processor rely on lapses or is held invalid, we and you will work together in good faith to use another lawful mechanism. If none is available, we will stop the transfer that depends on it.

B12 Government requests

B12.1 If a government asks us for your Content, we follow the Law Enforcement Guidelines in Section 25 (Government requests, safety reports and copyright) of the Privacy Policy.

B12.2 We disclose Content only with your consent or on a warrant for Content, except for emergency disclosures and reports to the National Center for Missing and Exploited Children, as the law allows. We give basic subscriber information on a subpoena and other records on a court order. We point the requester to you. Where the law allows, we tell you before we disclose anything, unless a court order forbids notice or there is an emergency, and we tell you after an order expires.

B12.3 We may challenge or narrow a request that is overbroad or defective.

B12.4 We cannot promise that data is beyond US legal process because it is hosted abroad.

B13 AI terms

B13.1 This is our commitment on training:

NATEX does not train models on your content. It sends requests that use your plan only to hosts that OpenRouter lists as zero-data-retention endpoints, which keep no prompts or replies to train on, apart from the exceptions stated in Section 6 of the Privacy Policy. If you choose to use your own AI account, requests on that account go to your provider, and your provider’s terms decide what it keeps. We do not keep a license to use your Content to train or improve models, and we do not use data from your Connected Services to train models.

B13.2 This is how AI requests are routed:

NATEX Work sends AI requests that use your plan only through OpenRouter, and only to model hosts that OpenRouter lists as zero-data-retention endpoints, meaning endpoints that keep no prompts or replies beyond serving the request, apart from the exceptions below. Every such request asks OpenRouter for both of its filters (zero data retention and no data collection), so if no such host can serve a request it fails instead of going elsewhere. NATEX does not train models on your content. It sends plan requests only to hosts that OpenRouter lists as zero-data-retention endpoints, which keep no prompts or replies to train on, apart from the exceptions below. If you choose to use your own AI account, requests on that account go to your provider instead, and your provider’s terms apply to them.

Those filters do not switch off a Model Host's own abuse and safety systems. Section 6 (AI Features and your information) of the Privacy Policy names the hosts that may keep or review a request, and for how long, and that statement is part of this DPA.

B13.3 Web search is different:

Web search is different: a short, cleaned search phrase (links, e-mail addresses and long numbers removed, never your workspace) goes to Perplexity through OpenRouter, and Perplexity states that it does not retain or train on API data.

B13.3A Two optional features change this. Workspace Memory is built only if a Member (Personal Memory) or an Admin (Team Memory) turns it on, only from Content the person it is built for can open, and it is part of Content under this DPA. If a Member connects an Own AI Account, that Member's requests go to the Own AI Provider the Member chose. That provider is not our Sub-processor. We send the Content to it on the instruction of the Authorized User who connected it, and the Customer is responsible for that instruction as it is for a Third-Party Agent (Section 12 (API, MCP Server and Webhooks) and Section 9.13). Admins cannot see a Member's Own AI Account, but an Admin can switch Own AI Accounts off for the whole Workspace, and while that switch is off we send no Content of that Workspace to an Own AI Provider. Group planning that involves more than one Member is always written by our plan models. We have no data processing terms with an Own AI Provider for you.

B13.4 Collections that are turned off for AI (by an Admin or a Member, or by default for health collections), records flagged "AI never touches this", and Student Data are removed on our servers from the Assistant, search and Teammates. This is the rule for Local-Only Mode:

Local-Only Mode stops the Assistant, search and Teammates in NATEX Work from sending your Content to AI. It does not govern calls you make through the API or Webhooks you configure.

B13.5 You decide which collections to exclude. Section 9 (AI Features) and Section 16 (Professional, regulated and government use) apply.

B14 Excluded data

B14.1 This DPA does not cover Prohibited Data. You must not put Prohibited Data into NATEX Work or send it to an AI Feature.

B14.2 NATEX Work is not for Protected Health Information, and we sign no business associate agreements. It is not for payment card numbers or security codes.

B14.3 If we find data like this, we may ask you to remove it, suspend the Account, and delete it on your instruction without reading it. Section 15 (Prohibited Data and Restricted Data) and Section 16 (Professional, regulated and government use) apply.

B14.4 A Seller's own payment instructions on an invoice or booking page are not Prohibited Data. Restricted Data may be in your Content. This DPA covers it as Content, but we give no assurance that NATEX Work fits the rules that apply to it.

B15 Customer duties

B15.1 You are responsible for:

• (a) the lawful basis for the Personal Information you put into NATEX Work, and the notices the law requires you to give the people it concerns;
• (b) giving us only lawful instructions;
• (c) the consents the law requires for recording, captioning, transcribing and AI processing of Calls and other Content; and
• (d) a notice about how you handle information on your forms, booking pages, invoices and other Public Pages. The line we add to a Public Page does not replace your notice.

B15.2 You give the people in your Content the Workspace owner's contact details and you honor their requests.

B15.3 Section 18 (Your duties to the people whose data you handle) says more.

B16 Liability and precedence

B16.1 Our liability under this DPA is subject to the limits in the Terms. For an Individual Customer, that is the cap in Section 29 (Limitation of liability). For an Organization Customer, it is the cap and the data-protection limit in Section 37 (Organization Customers: liability and indemnity), as Section 37.3 sets it.

B16.2 We give no uncapped indemnity for data. Nothing in this DPA limits a liability that the law forbids limiting.

B16.3 On how we process Personal Information in Content, this DPA prevails over the Terms. For billing, Schedule 1 controls. For conduct, the AUP controls. For disputes, Section 31 (Arbitration and class action waiver) controls.

B17 Regulated customers

B17.1 If you are a financial institution, an investment adviser, a tax preparer or an insurance licensee, Section B5 (Security measures) and Section B7 (Security Incident notice) are the contract terms you need to oversee us as an outside vendor. The 72-hour notice in Section B7 (Security Incident notice) is the notice period for a Security Incident that affects your Content.

B17.2 We give no assurance that you or we comply with the Gramm-Leach-Bliley Act, Regulation S-P, state insurance data security laws or Internal Revenue Code section 7216. You remain responsible for your own regulatory duties. Section 16 (Professional, regulated and government use) says more.

B18 How the DPA takes effect

B18.1 This DPA is part of the Agreement by reference. It takes effect on the day you accept the Terms, or on the day you begin to use the Service for a business, whichever is later. You do not sign it. The Acceptance Record is the record of your acceptance.

B18.2 This DPA is also published as its own page at /legal/dpa, and its earlier versions are at /legal/history.

B18.3 If you are on the Business or Scale Paid Plan and want a countersigned copy, email nshulman@natex.ai. We will sign it.

Annex B-1. Details of processing

Annex B-2. Security measures

The security measures are those in Section B5 (Security measures). Annex B-2 is that section.

End of Annex B. Effective Date: [[OPEN-01]]