Data processing addendum

This addendum applies when Ayion processes personal data on a customer’s behalf, under a pilot agreement or a subscription. It forms part of that agreement. Where this addendum and the agreement disagree about the handling of personal data, this addendum applies.

If you want a countersigned copy, or a version to send to your own counsel, write to hello@ayion.ai.

The short version

• You decide what personal data enters the platform and why. We process it only to provide the service and only on your instructions.
• Everything a customer’s agents do is recorded in an append-only evidence ledger. That ledger is designed so you can verify it without us.
• Our sub-processors are named below. You are told before a new one starts.
• We hold no security or AI management certifications today. This page says so rather than implying otherwise.
• At the end, you get your data back and we delete our copies.

Roles and scope

For personal data you put into the platform, or that the platform reads from your systems, you are the Data Fiduciary under India’s Digital Personal Data Protection Act, 2023, and the controller under the UK and EU General Data Protection Regulation where those apply. Ayion is the Data Processor and processor.

For the personal data of your staff who administer the service, and for our own business records, we act for ourselves. That processing is described in our privacy notice.

This addendum does not cover personal data collected through our website, which the privacy notice covers instead.

What we process, and why

Subject matter and duration. Providing the platform, for the term of the agreement and the retention period that follows it.

Nature and purpose. Running agents on work you have authorised, applying controls to the actions they take, recording those actions, reconciling them against your systems of record, and producing evidence for you and for the people you have to satisfy.

Categories of data. Whatever your workflows touch. That usually means the business records an agent acts on and the identifiers inside them, the identities of the people who approve actions, and the contents of connected systems within the scope you configure. Special category data and health data only where the agreement says so.

Categories of data principals and data subjects. Your staff, your customers, your suppliers, and any other person whose records are in the systems you connect.

You choose the scope. The platform is designed so that a connector, a pack and an operating contract each declare what they may read and what they may change, and we ask you to scope them to the minimum the work needs.

Our instructions

We process personal data only on your documented instructions, which are the agreement, this addendum, and the configuration you set in the platform. If we believe an instruction breaks applicable data protection law, we tell you and may pause that processing until it is resolved.

We do not sell personal data, use it for advertising, or use your data to train models. Your content is not used to improve any model, ours or a provider’s, and model calls made on your behalf are routed with training disabled where the provider offers that control. Where a provider does not offer it, that provider is not used for your data.

Our staff who can access personal data are bound by confidentiality obligations that survive the end of their engagement, and access is limited to the people who need it for a specific task.

Security

We apply, at minimum:

• encryption in transit and at rest
• access limited to named people, with two-factor authentication on every account that can reach customer data
• tenant isolation, so one customer’s data and keys are not reachable from another’s context
• an append-only, hash-chained evidence ledger, with customer-held keys, designed so a record can be verified by a third party without our involvement
• separation between the systems that act and the systems that record, so the party taking an action is not the sole author of the record of it
• logging of administrative access to customer environments

What we do not have. No SOC 2 report, no ISO/IEC 27001 certificate and no ISO/IEC 42001 certificate. Nothing in this platform ships in enforce mode — where a control can block a real action in your system — without an external penetration test first. If your procurement process requires a certification we do not hold, it should rule us out today, and we would rather you found that out here than in month three.

Sub-processors

These providers process personal data for us in order to run the service:

• Cloudflare hosts the website and the platform edge, and routes email sent to our addresses.
• Supabase stores contact and pilot enquiries, in its Mumbai region.
• Resend delivers transactional and notification email. Delivery may happen outside India.
• Google provides Gmail, where our team reads and keeps email. Email may be stored outside India.

Model providers and any customer-specific infrastructure are named in the agreement for your deployment, because they depend on the routing and data-location rules you choose. Where you supply your own model credentials, that provider is your sub-processor rather than ours.

We tell you at least 30 days before a new sub-processor starts processing your personal data. If you object on reasonable data protection grounds within that period, we will either propose an alternative or let you terminate the affected part of the service without penalty.

Transfers

Where personal data is processed outside the country it came from, we do so as the applicable law permits, using the transfer mechanism that law requires. You can ask for the specific mechanism in use for your deployment, and the platform’s model gateway is built to route by data location so that a workload can be kept in a region you choose.

Requests from data principals and data subjects

Requests come to you, not to us. If one reaches us directly, we will not answer it on your behalf; we pass it to you without undue delay.

We help you answer them. Because every consequential action is recorded with its parameters, its authority and its reconciliation, the record of what was done to a person’s data is designed to be retrievable rather than reconstructed. Where you ask us to correct or erase personal data, we do so within the platform, and the erasure itself is recorded as an entry rather than by removing history.

Personal data breaches

If we become aware of a personal data breach affecting personal data we process for you, we tell you without undue delay and in any case within 48 hours of becoming aware. We give you what we know: what happened, which categories and roughly how many records are affected, the likely consequences, and what we are doing about it. We keep telling you as we learn more.

Notifying your regulator and the people affected is your decision and your obligation. We give you the information you need to make it.

Audits and information

On reasonable notice, and no more than once a year unless a regulator or a breach requires otherwise, we will give you the information you need to show this addendum is being met. That includes answering a security questionnaire, walking your team through the controls, and giving a read-only auditor view of the evidence for your own tenant.

Where an on-site or system audit is required by law or by your regulator, we will cooperate and agree the scope with you in advance.

Return and deletion

At the end of the agreement you may export your data, including the evidence ledger for your tenant, in a machine-readable form. We delete our copies within 90 days of the end of the agreement, or return them first if you ask, except where a law requires us to keep something, in which case we tell you what and for how long.

Deletion of the ledger is deletion of your record. If you need it for a retention obligation, export it first.

Health data

Where a deployment involves health data, including JhiOn, the additional handling, consent and disclosure terms are set out in the agreement for that deployment, and the limits on what the product does are in our health information disclaimer. Health data is not processed under this addendum alone.

Liability, changes and contact

Liability under this addendum is governed by the liability terms of the agreement it forms part of.

We may update this addendum where the law changes or our processing changes. When we do, we update the version and effective date at the top of this page and tell customers in advance of anything material.

The governing entity’s registered name and address, and a countersigned copy of this addendum, are provided on request: hello@ayion.ai.