Data Processing Agreement

Controller: the customer who accepts the Terms of Service ("you").

• Subject: processing personal data contained in the material you upload and in what the Service generates from it, in order to run simulations, generate reports and answer chats.
• Nature: storage, analysis by AI models, anonymization and renaming when you enable them, generation of output, deletion.
• Data subjects: people named or described in your material.
• Categories of data: whatever your material contains, typically names, roles, opinions and statements. You must not upload special categories of data (art. 9 GDPR) or data about criminal convictions unless you have a legal basis and have told us in writing.
• Duration: for as long as the contract lasts and, for each simulation, until you delete it or your account.

We process the data only on your documented instructions, which are the Terms of Service, this agreement and the settings you choose in the Service (for example running, branching or deleting a simulation, enabling anonymization or fictional names). If we believe an instruction infringes data protection law, we tell you. We do not use your material for any other purpose, and we do not use it to train AI models.

Only the processor and the people authorised by him access the data, and only as far as needed to provide the Service or support you. Everyone with access is bound to confidentiality.

• Encryption of all traffic with HTTPS (TLS).
• Server-side verification of every request against the signed-in session; each simulation, report, chat and live update is available only to the account that created it.
• Cached AI answers kept separate for each simulation and deleted with it.
• Database and application not reachable from the internet directly; firewall open only for the website, the API and administration.
• Password-protected in-memory store, also written to the server's disk to survive restarts; entries expire on their own and are deleted with their simulation.
• Request rate limits, HTTP security headers, monitoring of AI usage with automatic alerts.
• Optional anonymization and fictional names, described in the Privacy Policy.

You give general authorisation to use the sub-processors below. We inform you by email before adding or replacing one, and you may object within 15 days; if we cannot accommodate the objection you may terminate the contract. We impose on each sub-processor data protection obligations equivalent to these.

AI providers may keep requests and responses for a limited period for safety and abuse monitoring, as described in the Privacy Policy.

If a person asks us to exercise their rights about data in your material, we forward the request to you without delay and do not answer it ourselves unless you instruct us. The Service lets you find, export and delete your simulations; for anything else we help you as far as reasonably possible.

We notify you without undue delay after becoming aware of a breach affecting your data, with the information available to us (what happened, data and people concerned, likely consequences, measures taken), and we keep you updated, so that you can meet your own obligations under articles 33 and 34 GDPR.

When you delete a simulation, it is erased immediately and permanently together with its source material, anonymization table, agents, memories, knowledge graph, chats and reports. When the contract ends or you delete your account, all your simulations are erased the same way. Records of AI costs are kept only without any link to you. If you want a copy of your data, export it before deleting.

We make available the information needed to demonstrate compliance with this agreement and allow audits by you or an auditor you appoint, bound to confidentiality, with at least 30 days' written notice, during business hours and without disrupting the Service. Each party bears its own costs.

Questions about this agreement: privacy@visionswarm.it.