Data Processing Agreement

“Controller” you, the Customer. You decide why and how personal data is processed.

“Processor” Amvio. We process personal data only on your documented instructions.

“Personal Data” any information relating to an identified or identifiable person that Amvio processes on your behalf under the Terms of Service.

“Data Protection Law” the EU GDPR, the UK GDPR and Data Protection Act 2018, the CCPA as amended by the CPRA, and any other law applicable to the processing.

1.1 Where the CCPA applies, Amvio is a service provider. Amvio does not sell or share Personal Data, does not retain, use or disclose it for any purpose other than performing the services, and does not combine it with data from other sources except as permitted.

2.1 Amvio processes Personal Data only to provide and support the service, and only on your documented instructions. The Terms of Service, your configuration in the dashboard, and this agreement are your complete instructions.

2.2 If Amvio believes an instruction breaches Data Protection Law, it will tell you and may pause that processing until the instruction is resolved.

2.3 If Amvio is required by law to process beyond your instructions, it will tell you first unless the law forbids it.

2.4 You warrant that you have a lawful basis for the Personal Data you put into Amvio and for the processing you instruct — including, where you enable voice or screen capture, any consent required from your end users before a session begins.

3.1 Amvio ensures that anyone authorised to process Personal Data is bound by confidentiality obligations and is granted access only where needed to do their job.

4.1 Amvio implements the technical and organisational measures described in Annex II, which are appropriate to the risk, and will not materially reduce them during your term.

5.1 You give general authorisation for Amvio to engage sub-processors. The current list is published and maintained at /privacy/subprocessors.

5.2 Amvio will give at least 30 days' notice before adding or replacing a sub-processor, by email to your account address. You may object on reasonable data-protection grounds within that period. If we cannot resolve your objection, you may terminate the affected part of the service and receive a refund for the unused remainder of the term.

5.3 Amvio imposes data protection obligations on each sub-processor no less protective than those in this agreement, and remains fully liable to you for their performance.

6.1 Data subject requests. Taking account of the nature of the processing, Amvio will assist you with appropriate technical and organisational measures in responding to requests to access, correct, delete, port or restrict Personal Data. If a request reaches Amvio directly, we will not respond to it substantively — we will route it to you.

6.2 Impact assessments.Amvio will provide reasonable assistance with data protection impact assessments and prior consultations with a supervisory authority, so far as it relates to Amvio's processing.

7.1 Amvio will notify you without undue delay, and in any event within 72 hours of becoming aware of a Personal Data breach affecting your data.

7.2 The notice will describe the nature of the breach, the categories and approximate number of records affected so far as known, the likely consequences, the measures taken or proposed, and a contact point. Where the full picture is not yet available, we will provide it in phases without undue further delay.

7.3 Amvio will not make any public statement identifying you in connection with a breach without your prior written consent, unless required by law.

8.1 On termination, Amvio will delete Personal Data within 30 days of your written request and within 90 days in any event, unless law requires it to be kept — in which case Amvio will isolate it and stop processing it for any other purpose.

8.2 Before deletion, and on request within 30 days of termination, Amvio will make Personal Data available to you for export.

8.3 Backups are deleted on their own rolling cycle rather than individually, and are never restored to serve a deleted workspace.

9.1 Amvio will make available the information reasonably necessary to demonstrate compliance with this agreement, and will respond to reasonable security questionnaires no more than once a year.

9.2 Where that is not sufficient for your regulator, you may audit — on 30 days' notice, no more than once a year unless a breach or a supervisory authority requires otherwise, during business hours, without disrupting the service, and subject to confidentiality. You bear the cost of the audit unless it reveals a material breach by Amvio.

10.1 Amvio is established in the United States and its sub-processors process data in the United States and elsewhere.

10.2 Where Amvio processes EEA Personal Data, the European Commission's Standard Contractual Clauses (Decision 2021/914), Module Two (controller to processor), are incorporated into this agreement. You are the data exporter and Amvio the data importer. Clause 7 (docking) applies; the optional Clause 9(a) wording is Option 2, general written authorisation with the 30 days' notice in clause 5.2 above; the Clause 11 independent dispute resolution option does not apply; the Clause 17 governing law is Ireland; and the Clause 18 forum is Ireland.

10.3 Where Amvio processes UK Personal Data, the UK International Data Transfer Addendum to those clauses is incorporated, with Tables 1 to 3 populated by this agreement and its annexes, and Table 4 marked “neither party”.

10.4 If a transfer mechanism is invalidated, the parties will work in good faith to put a valid alternative in place.

11.1 Subject matter and duration. Provision of the Amvio customer success agent, for the term of the Terms of Service plus the deletion window in clause 8.

11.2 Nature and purpose. Hosting, storage, indexing, retrieval, generation of responses, and analysis of conversations to produce dashboard reporting.

11.3 Categories of data subject. Your personnel who use the dashboard, and your end users who interact with the Amvio widget inside your product.

11.4 Categories of Personal Data. Names and email addresses; account and user identifiers you supply; the full content of conversations; inferences drawn from them, including sentiment and risk signals; technical data such as IP address and device information; and, where you enable it, voice recordings and images of an end user's screen.

11.5 Sensitive data. None is intended or required. Amvio is not built for special-category data, and the Acceptable Use Policy prohibits putting it in. Because conversations are free-form, an end user may nonetheless volunteer something sensitive; Amvio does not solicit, index or single out such data.

11.6 Frequency. Continuous, for the duration of the service.

11.7 Retention. As set out in the Privacy Policy section 7: for the life of the workspace, then deleted per clause 8.

12.1 Encryption. All data encrypted in transit with TLS. Data at rest encrypted by the database and storage provider.

12.2 Tenant isolation.Enforced in the database itself by row-level security policies keyed to organisation membership, so a query cannot reach another tenant's rows even if application code is wrong.

12.3 Access control. Role-based access within a workspace (owner, admin, member). Mutations to organisations, members and invitations run through privileged database functions rather than direct table writes, so the invariants are enforced in one place.

12.4 Key handling. Server-side secrets are generated server-side, never sent to the browser, and cannot be read back after generation — only rotated. Identity assertions from your servers are signed and verified with a constant-time comparison, with an overlap window so keys can be rotated without downtime.

12.5 Segregation. Test and development data are kept in separate databases; production credentials are not used in development.

12.6 Resilience. Managed database backups held by the infrastructure provider, with point-in-time recovery.

12.7 Logging. Application and access logs retained for security and debugging, with errors reported to an internal endpoint rather than a third-party analytics service.

12.8 Sub-processor governance. The published list at /privacy/subprocessors is maintained alongside the code, and notice is given before it changes.

12.9 The security overview states plainly what Amvio has not done — including which certifications it does not hold. Read it before completing a vendor assessment.

13.1 If this agreement conflicts with the Terms of Service on the processing of Personal Data, this agreement controls.

13.2 Amvio's liability under this agreement is subject to the limitations in clause 9 of the Terms of Service.

13.3 If you need this executed as a signed counterpart for your records, write to hello@amvio.ai.