Data Processing Agreement

Applies to: Team Asta — the website at teamasta.com and the Asta app at teamasta.com/app. Version: 2.4 · Effective: 10 November 2026

This Data Processing Agreement ("DPA") records the terms required by Article 28(3) of Regulation (EU) 2016/679 ("GDPR") for our processing of personal data on your behalf.

It forms part of the Team Asta Terms and Conditions (the "Terms") and is accepted when you accept them. Capitalised terms not defined here have the meaning given in the Terms. It is a different document from our Privacy Notice, which describes the processing we carry out as controller in our own right.

Parties. Agentic Agency ApS, CVR 46326458, Gammel Kongevej 152 B, 3., 1850 Frederiksberg C, Denmark ("we", "Processor") and the organisation that has accepted the Terms ("you", "Controller").

Precedence. Where this DPA and the Terms conflict on the processing of personal data, this DPA prevails. Where this DPA and the Standard Contractual Clauses conflict, the Standard Contractual Clauses prevail.

1. Subject matter, duration, nature and purpose

Art. 28(3), opening paragraph.

1.1 The subject matter is our processing of personal data contained in Customer Data in order to provide the Service.

1.2 The duration is the term of the Terms, plus the period in clause 9 for return and deletion.

1.3 The nature and purpose is the operation of an AI assistant and of the project features offered with it: keeping a working copy of the mail, calendar and contacts of the accounts you connect and acting in them on your instructions; storing your files, notes, conversations and work items; conducting typed and spoken conversations with you and, in projects, with the individuals you name; and returning the results to you.

1.4 The types of personal data and categories of data subjects are set out in Annex I.

2. Roles

2.1 In respect of Customer Data — including the mail, calendar entries and contacts of your Connected Accounts, your files and notes, your conversations and calls with Asta, the contacts you enter and the answers Participants give — you are the controller and we are the processor.

2.2 You are responsible for the lawfulness of the processing you instruct: for having a lawful basis to process the personal data in your Connected Accounts with the Service, to contact the individuals you name and to process their responses, and for giving data subjects the information Articles 13 and 14 GDPR require. Clauses 6, 7 and 8 of the Terms set this out.

2.3 We process personal data about your Authorised Users for our own purposes — account administration, security, support and billing — as controller. That processing is outside this DPA and is described in our Privacy Notice.

2.4 Neither of us is a joint controller with the other within the meaning of Article 26 GDPR.

3. Processing on documented instructions

Art. 28(3)(a).

3.1 We process personal data only on your documented instructions, including as to transfers to a third country, unless required to do otherwise by Union or Member State law — in which case we will tell you of that requirement before processing, unless the law prohibits it on important grounds of public interest.

3.2 The Terms, this DPA, and your use of the Service through its interfaces together constitute your documented instructions. Connecting an account, giving Asta a task, answering a decision or plan, authorising Asta to send or act on your behalf, setting up a project, creating an interview link or sending a message is an instruction.

3.3 We will tell you if, in our opinion, an instruction infringes the GDPR or other Union or Member State data protection law. We may suspend the affected processing until the instruction is withdrawn or amended.

3.4 We do not use Customer Data for our own purposes. In particular we do not use it to train or improve models, and neither may our AI providers: Anthropic is prohibited by its commercial terms from training models on Customer Data, and under OpenAI's API terms data sent through its API is not used for training unless the customer opts in, which we do not. Data received from Google APIs is in addition handled under the Limited Use requirements set out in section 5 of the Privacy Notice. We will not change the positions stated above without notice under clause 6.2.

4. Confidentiality

Art. 28(3)(b).

4.1 We ensure that persons authorised to process personal data under this DPA are bound by an appropriate obligation of confidentiality, whether contractual or statutory, and that the obligation survives the end of their engagement.

4.2 Access to Customer Data in production is limited to the personnel who need it to run the Service, to resolve a fault, or to act on your instruction. Our staff do not read Customer Data as a matter of routine.

5. Security

Art. 28(3)(c), and Art. 32.

5.1 We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, taking account of the state of the art, the costs of implementation, and the nature, scope, context and purposes of the processing.

5.2 The measures in place are described in Annex II. That annex states both what is implemented and what is not. It is accurate as at the version date at the top of this document and will be updated as measures change.

5.3 The Service is offered in early access. Clause 3 of the Terms describes what that means, and Annex II should be read as the security position of an early-access service, not of a certified production platform.

6. Subprocessors

Art. 28(2), Art. 28(3)(d) and Art. 28(4).

6.1 You give us general authorisation to engage subprocessors. Those engaged at the version date of this document are listed in Annex III, with what each is used for and where it processes. The providers of your own Connected Accounts (such as Google) are not our subprocessors: you engage them, and we access their services on your instructions.

6.2 We will give you reasonable advance notice before adding or replacing a subprocessor that processes Customer Data, by publishing a new version of Annex III, as clause 20 of the Terms describes, before it starts. You may object on reasonable data protection grounds within 30 days of being shown that version, also after accepting it. If we cannot resolve the objection, either of us may terminate the affected part of the Service without penalty, and clause 9 applies.

6.3 We impose on every subprocessor, by written contract, data protection obligations no less protective than those in this DPA, and we remain fully liable to you for their performance.

7. Assisting you with data subject requests

Art. 28(3)(e).

7.1 Taking account of the nature of the processing, we assist you by appropriate technical and organisational measures, insofar as possible, to respond to requests to exercise rights under Chapter III GDPR — access, rectification, erasure, restriction, portability and objection.

7.2 Where a data subject makes such a request to us directly, we will not respond to it on the substance. We will tell them without undue delay to approach you, and tell you that the request was made, unless the law prevents it.

7.3 Section 13 of the Privacy Notice tells data subjects exactly this: the customer whose mail, calendar or project holds their data is the one who must act on their request, and if they cannot identify that customer we will identify you and pass the request on.

8. Assisting you with security, breaches and impact assessments

Art. 28(3)(f), covering Arts. 32-36.

8.1 We notify you of a personal data breach affecting Customer Data without undue delay and in any event within 48 hours of becoming aware of it, with the information you need to meet your own obligations under Articles 33 and 34 — the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, and the measures taken or proposed.

8.2 We assist you, taking into account the nature of the processing and the information available to us, in ensuring compliance with Articles 32 to 36 — including data protection impact assessments and prior consultation with a supervisory authority.

8.3 Notification under clause 8.1 is not an acknowledgement of fault or liability.

9. Return and deletion

Art. 28(3)(g).

9.1 At your choice, we delete or return all personal data processed on your behalf at the end of the provision of the Service, and delete existing copies, unless Union or Member State law requires storage.

9.2 You can download your files and documents at any time during the term; we provide anything further on request. Mail, calendar entries and contacts remain in your Connected Accounts. Clause 16 of the Terms describes export and switching.

9.3 Unless you ask for return, we delete Customer Data within 30 days of the end of the term. Volume snapshots are normally deleted after about four days (Annex II); data in a snapshot is not restored to active use.

9.4 We act on a deletion request from you during the term without undue delay. You can also delete your account yourself, in Settings: that deletes the Customer Data it holds at once, including what Anthropic holds for it under 9.5, as section 9 of the Privacy Notice describes. When you disconnect a Connected Account (in Settings or by asking Asta), we stop accessing it and delete the access we held; the copy of its mail and calendar is deleted at once or kept, as you choose (section 5.4 of the Privacy Notice).

9.5 Customer Data that Anthropic holds for us under Claude Managed Agents (session history, including the results of Asta's tools; files in the session; and Asta's memory stores, the notes Asta keeps for itself across conversations, one for each user and one for each workspace, and one for each Participant in a written interview) is stored by Anthropic in the United States until we delete it through Anthropic's API. We delete it when the account is deleted (9.4) and at the end of the Service under clause 9.1, and otherwise on your request. Where the account shares a workspace with others, what belongs to that workspace stays until the workspace goes. We have not fixed an automatic deletion schedule and state no period.

How deletion works today. Customer content has no automated deletion schedule, with these exceptions: the nightly removal from our copy of a connected mailbox of mail in threads with no activity for 365 days, unless it is marked to be kept, and of cached attachments and the HTML of the oldest mail when that copy outgrows its storage limit; the removal of older versions of a file beyond the newest ten after 30 days; the removal of call records at Voice Call 90 days after the call was ordered; the removal of a browser profile about 30 days after it was last used; and the removal of technical records of our services after 7 to 35 days. You delete an account and its data yourself, in Settings (9.4); anything else under this clause is deleted by us, on request. This is recorded in section 9 of the Privacy Notice. It does not reduce the commitment in 9.1 to 9.4.

10. Information and audits

Art. 28(3)(h).

10.1 We make available to you the information necessary to demonstrate compliance with Article 28 — this DPA, its annexes, and our security documentation.

10.2 You may audit that compliance once in any twelve-month period, on 30 days' written notice, during business hours, without unreasonable disruption, and subject to confidentiality. You bear your own costs; we bear ours. Where a supervisory authority requires it, an audit may be conducted more often and on shorter notice.

10.3 An auditor you appoint must not be a competitor of ours, and must accept the same confidentiality obligations.

10.4 We hold no ISO 27001 or SOC 2 certification, and we do not claim one. Where that matters to you, say so before you rely on the Service.

11. International transfers

11.1 We transfer personal data outside the EU/EEA only where a valid Chapter V transfer mechanism applies — an adequacy decision, the EU–US Data Privacy Framework where the recipient is certified, or the Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914), with the supplementary measures the transfer requires.

11.2 The subprocessors in Annex III that process outside the EU/EEA are marked as such, with the mechanism relied on. A copy of the relevant mechanism is available on request from privacy@agenticagency.dev.

11.3 Where the Standard Contractual Clauses apply between us, Module Two (controller-to-processor) is incorporated, with Annex I of this DPA as their Annex I, Annex II as their Annex II, and Annex III as their list of subprocessors. The governing law is Danish law and the forum is the Danish courts.

12. Term, liability and general

12.1 This DPA takes effect when you accept the Terms and continues for as long as we process personal data on your behalf.

12.2 Each party's liability under this DPA is subject to the limitations and exclusions in clause 19 of the Terms. Nothing in this DPA limits a data subject's rights under Article 82 GDPR.

12.3 We may update this DPA where a change in law, in the Service or in our subprocessors requires it. Material changes are made known and accepted in the app, as clause 20 of the Terms describes. The version number and effective date at the top identify the current text, and each published version is tied to the release it shipped in.

12.4 This DPA is governed by Danish law, and clause 22 of the Terms governs jurisdiction.

Annex I — Details of the processing

Categories of data subjects

• Your Authorised Users.
• People whose personal data is in your Connected Accounts — those who write to you or whom you write to, attendees of your calendar entries, and your contacts.
• Participants — the individuals you name and an Agent contacts, who may respond without registering.
• Any individual whose personal data appears in a file or note, a conversation, a call or a Participant's answer.

Types of personal data

• Mail: sender, recipients, subject, date, body and attachments of messages in your connected mailbox, and drafts and messages written by Asta.
• Calendar: events with title, time, place, description and attendees.
• Contacts: names, email addresses, phone numbers and other details from your connected account and from your correspondence, and the notes Asta keeps about contacts for you.
• Files and notes: whatever personal data the files you upload or Asta writes happen to contain. You control this entirely; we do not inspect it.
• Conversation content: your chats with Asta, and the transcripts of every chat and voice conversation — with Asta and, in projects, with Participants.
• Voice audio: processed in real time during a voice conversation; not recorded by us.
• Work items: to-dos, decisions and reminders, and the sources Asta watches for you.
• Asta's memory: what Asta notes for itself about you, your work and the people you deal with, to remember across conversations; the workspace's rules and the notes our team takes in a set-up call; and what an agent notes about a Participant in a written interview.
• Browsing data: pages Asta opens for you, and logins and cookies you save in the browser Asta uses for you.
• Project data: contact records (name, email address, optionally organisation and a note), interview link metadata (goal, expected result, expiry and a hash of the link token; the token itself is never stored), and results.

Special categories of personal data

None is intended or requested, and clause 9 of the Terms restricts what you may submit deliberately. Such data can nonetheless reach the Service — in mail you receive, in a calendar entry, or in what a Participant volunteers. We process it under the same measures as all other Customer Data.

Nature and purpose of the processing

Collection from your Connected Accounts, storage, organisation, retrieval, sending of mail and changes to calendar entries on your instructions, transmission by email, disclosure to the AI model, web search and speech providers listed in Annex III for the purpose of carrying out your instructions, transcription, and return of the results to you.

Frequency — continuous, for the duration of the Terms.

Duration — as clause 9.

Retention — as section 9 of the Privacy Notice.

Annex II — Technical and organisational measures

Art. 32 GDPR. This annex states what is implemented and what is not. It describes an early-access service and should be read as such.

Hosting. The Service runs on OVHcloud Managed Kubernetes in Germany. Its databases, files and backups stay in that region.

Encryption in transit. All traffic to the Service is served over TLS, with certificates issued by Let's Encrypt and renewed automatically. Connections to our AI, speech and email subprocessors and to Google are over TLS. The app sets Strict Transport Security.

Encryption at rest. The databases and file volumes holding Customer Data are OVHcloud block-storage volumes of the LUKS-encrypted class, encrypted server-side with an OVHcloud-managed key per volume; their nightly snapshots inherit that encryption. The access tokens for Connected Accounts, the keys for our internal services and the saved state of a paused browser are in addition encrypted by the application (AES-256-GCM). Not encrypted at rest: the database of our sign-in service (identities and password hashes), which is on a volume of the unencrypted class, and the sign-in tokens of active web sessions and the browser profile Asta uses, with its logins, which are protected only by the volume encryption.

Authentication and credentials. Sign-in runs on our own sign-in service with the authorisation code flow and PKCE. It stores passwords only as hashes and is protected against password guessing. The app's session cookie is HTTP-only, signed, and carries only a random session id; the tokens stay on the server, and sessions end after 12 hours or at sign-out. Keys that are presented to us and one-time tokens are stored only as hashes. Keys are issued only by our team. Interview link tokens are stored only as hashes, so a copy of the database yields no working links.

Access control. Access to production is limited to the personnel who need it. Automated deployment runs through a Kubernetes service account limited, namespace by namespace, to what a rollout needs. Application secrets are held as Kubernetes Secrets, not in the image or the repository. The app's container runs as a non-root user without added privileges.

Tenant isolation. Every record belongs to an account, directly or through the record above it, and the application scopes queries and file paths to it. Our team's admin tools read across accounts. There is no database-level row security; isolation is enforced by the application. Interview links are scoped to a single project; a Participant sees only the project they were invited to.

Request limits. Sign-in, the chat with Asta, the tool interface and calls with Asta are rate-limited per user, key or address, and every voice call has a maximum length. Interviews by chat or voice have no rate limit of their own yet.

Security headers. The app sets Strict Transport Security, X-Content-Type-Options and X-Frame-Options; the website and the Core's interface do not set them themselves. A Content Security Policy is not set.

AI disclosure. Participants are told they are interacting with an AI system before the conversation starts, as Article 50(1) of Regulation (EU) 2024/1689 requires and clause 8.3 of the Terms promises.

Logging. Application and access logs, including IP addresses, are kept for operational and security purposes. Transcripts of voice calls are not written to logs.

Backups. Persistent volumes are snapshotted nightly; snapshots stay in the same OVHcloud region. The last four nights of each volume are kept, so a snapshot normally goes after about four days; if a night's snapshot fails, the older ones stay until a new one works.

Availability. The Service runs on managed Kubernetes with automated rollout and health checks. Deployments are versioned by image tag, and the running version is publicly verifiable.

Development practice. Review and an automated test suite before merge are our working rule; the repository does not enforce them. Releases of the app are built by CI from a tagged commit.

Deletion. An account holder deletes their account in Settings, or on the screen that asks them to accept a new version of the Terms, after confirming it with their email address. The deletion first blocks new calls with Asta, ends a running one and removes the sessions of the account's voice calls at Anthropic. It then revokes the stored keys and removes the sessions and memory stores at Anthropic (of workspaces that go, and the account's own conversations), the files in our file service and the mail and calendar copies of connected accounts (asking the provider to revoke our access). It then removes the Core's records, closes open checkouts and cancels the subscription at Stripe (the customer record stays as a billing record), removes the app's records and the account's directories and, last, the sign-in record at our sign-in service. Up to the removal of the app's records it can be repeated until every step is done; if removing the directories or the sign-in record fails after that, the failure is recorded and our team finishes the step by hand. What the account wrote to everyone in a shared workspace stays there, with the name. The deletion leaves a deletion record without name, email address or plain account id, as evidence of the deletion. A Connected Account is disconnected in Settings, with the choice to delete its mail and calendar copy at once.

Measures not currently in place. Stated explicitly, because their absence is part of an accurate description:

• No encryption at rest for the database of the sign-in service (see above).
• No Content Security Policy.
• No database-level row security (isolation is enforced by the application).
• No formal periodic access review, and no documented access-revocation procedure.
• No independent penetration test or vulnerability assessment.
• No general automated data-deletion job — see clause 9. (Self-service account deletion is in place: clause 9.4.)
• Account deletion does not yet delete the browser profile Asta used for the account (it is locked with the account and deleted about 30 days after it was last used, or on request), or the disabled user records in our file service and the service behind Asta's browser.
• No off-site copy of backups; snapshots stay in the same region.
• No fixed retention period for application and access logs.
• No certification against ISO 27001, SOC 2 or an equivalent scheme.

Annex III — Subprocessors

As at the version date at the top of this document.

Mail that Asta sends for you goes out through your own mailbox at the provider of your Connected Account, not through Mailjet.

Changes to this list are notified under clause 6.2.

Agentic Agency ApS · privacy@agenticagency.dev Gammel Kongevej 152 B, 3., 1850 Frederiksberg C, Denmark · CVR 46326458