Data processing agreement

This agreement is for businesses that use the online model of a Uvinta Cloud subscription for text that holds personal data of other people, such as clients, colleagues or the people in a call. It is part of the Uvinta license (section 14) and is already accepted by us, so you need not sign anything: it applies as soon as you use the subscription’s model in your business. Keep the PDF for your records. If you need a copy signed by us, write to info@uvinta.com.

The processor: , , the publisher of Uvinta, info@uvinta.com (“we”). The controller: the business that bought the subscription (“you”).

1. What this agreement covers

Uvinta works with local models on your Mac and, with a subscription, also with an online model reached through our service. Only the second brings your data to us: the text Uvinta sends to the subscription’s model and the answers that come back (“your text”). For your text you are the controller, or a processor acting for your own client, and we are your processor, or sub-processor, under Article 28 of the GDPR.

This agreement does not cover what Uvinta does on your Mac alone (speech recognition, the voice, the local models, saved sessions and recordings), which never reaches us; the data of your purchase, your account and your subscription, which we handle as a controller under our privacy policy; or the payment, which Paddle handles as an independent controller.

2. The processing (Annex 1)

3. Our duties

• We process your text only to provide the features of Uvinta you use, which are your documented instructions, unless EU or Polish law requires otherwise; we then tell you first, unless that law forbids it. Your instructions include the transfers described in section 5. We tell you if we think an instruction breaks data protection law.
• We do not store your text or the answers, do not write them to logs, do not use them to train or improve models, and do not sell or share them.
• Only the publisher has access to the service. Anyone we let help with it is bound to confidentiality first.
• We keep the security measures of Annex 2.
• We help you, as far as we reasonably can, to answer the requests of data subjects and to meet Articles 32 to 36 of the GDPR. As we keep none of your text, most requests concern data you hold yourself.
• We tell you without undue delay, and at most 48 hours after we learn of it, of a personal data breach that affects your text, with what we know and what we are doing about it.
• We give you the information you need to show that this agreement is kept and answer your questions about it in writing. If that is not enough, an auditor bound to confidentiality may check it once a year, at your cost, after 30 days’ notice.
• When your subscription ends, nothing of your text remains with us to return or delete.

4. Sub-processors (Annex 3)

You allow us to use the sub-processors listed in Annex 3. Cloudflare and OpenRouter are bound to us by their data processing agreements, with duties no weaker than these. The model’s hosts work for OpenRouter under its agreements with them, not under a contract with us: we let OpenRouter send your text only to hosts it lists as not using requests to train models, and to no other host. A host may keep a request for a short time to run and protect its service. We remain responsible to you for what our sub-processors do with your text. We announce a new or replaced sub-processor at least 14 days before it starts, on this page and by email to the address of your subscription. If you object to it for a reason of data protection, you may end the subscription before the change and get back the price of the unused part of the paid month.

5. Transfers outside the European Economic Area

OpenRouter and the model’s hosts process your text in the United States, and Cloudflare’s network may carry it there too. These transfers rest on the EU–US Data Privacy Framework where the recipient is certified under it, and otherwise on the European Commission’s standard contractual clauses in the recipient’s data processing terms (GDPR Article 46).

6. Your duties

You make sure that there is a lawful ground for sending your text to the subscription’s model, that the people concerned are informed as the law requires (for example the participants of a call you interpret), and that Uvinta is used only under this agreement and the license.

7. California

Where the California Consumer Privacy Act applies, we are your service provider: we do not sell or share personal information from your text, do not keep, use or disclose it for any purpose other than providing the features of Uvinta, and do not combine it with other data.

8. Liability, term and law

Liability under this agreement follows section 10 of the license; nothing here limits what the GDPR gives the data subjects. This agreement lasts as long as your subscription. Where it differs from the license on the protection of personal data, this agreement comes first. It is governed by the law of Poland, and disputes go to the court that has jurisdiction over our seat. We may change it to follow the law or a change of sub-processors; a change that lowers your protection is announced as section 4 says. If you do not accept a change, you may end the subscription before it applies and get back the price of the unused part of the paid month.

Annex 2: Security measures

• Every connection between Uvinta, our service, OpenRouter and the model’s host is encrypted (HTTPS, TLS 1.2 or later).
• Uvinta reaches the model only with a pass we sign for one Mac, good only for the paid period. Our key to OpenRouter never leaves the service and is stored encrypted.
• The service passes on only the fields the features need, with its own choice of model. It asks OpenRouter only for hosts that do not keep data to train models, and allows no other host as a fallback.
• Your text and the answers stay in the service’s memory only while a request runs. The service writes no request content to logs or storage.
• Speech is recognized on your Mac: audio never reaches us. Only the recognized text does, when you use the subscription’s model.
• Only the publisher can reach the accounts behind the service (Cloudflare, OpenRouter, Paddle). The service’s secrets are kept in Cloudflare’s encrypted secret store.
• A request to the model needs a pass issued to one Mac, is limited in size and counts against the plan’s monthly allowance; sign-in and the site’s forms are limited per network.
• Vulnerabilities are handled as our security page describes.

Annex 3: Sub-processors