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Meet the new Kincode AI websiteWhy we rebuilt Kincode AI’s website around a faster, AI-first way of working.Read the story LegalPrivacy policyTerms and conditionsData Processing AddendumLegal centre Purpose and scope This Data Processing Addendum (DPA) governs Kincode AI’s processing of Customer Data on behalf of the customer in connection with the services. It forms part of the agreement between the customer and Kincode AI. Definitions Customer Data means personal data that Kincode AI processes on the customer’s behalf through the services. Data Protection Laws means the data protection laws and regulations applicable to a party’s processing of Customer Data, including EU Data Protection Law and applicable non-EU laws. EU Data Protection Law includes the General Data Protection Regulation (GDPR), applicable national implementations, and relevant UK, EEA, and Swiss data protection requirements. SCCs means the standard contractual clauses approved by the European Commission or applicable Swiss authority for restricted transfers of Customer Data. Services Data means data relating to the customer’s use, support, and operation of the services, including activity logs, volumes, and usage information. Roles of the parties Where applicable Data Protection Laws apply, the customer is the controller and Kincode AI is the processor of Customer Data. Kincode AI will process Customer Data only on the customer’s documented instructions, as necessary to provide the services, comply with applicable law, or as otherwise agreed in writing. Categories and sources of Customer Data Customer Data may include account and profile information supplied by the customer or imported through customer-connected services. Where the customer connects a messaging platform or single sign-on (SSO) provider, Kincode AI may import users’ profile photos from that service to display their user profiles as part of the services. Permitted processing The agreement and the customer’s documented instructions form the complete and final instructions for processing Customer Data. Kincode AI will not process Customer Data outside those instructions unless required by applicable law or agreed in writing. Customer responsibilities The customer is responsible for the accuracy, quality, legality, and collection of Customer Data, including providing required notices and obtaining any consents or rights necessary for Kincode AI to process the data. The customer must not provide Sensitive Data for processing under the agreement unless the parties agree otherwise in writing. Instructions that may breach the law The customer must ensure that its processing instructions do not require Kincode AI to violate applicable Data Protection Laws. Kincode AI will promptly notify the customer if it becomes aware that an instruction may breach applicable law, unless prohibited from doing so. Confidentiality and security Kincode AI will ensure that people authorized to process Customer Data are subject to appropriate confidentiality obligations. Kincode AI maintains administrative, physical, and technical safeguards designed to protect Customer Data against loss, misuse, unauthorized access, disclosure, alteration, and destruction. International transfers Where Customer Data is transferred outside the European Economic Area, the United Kingdom, or Switzerland, Kincode AI will use an appropriate transfer mechanism under applicable Data Protection Laws, including the SCCs where required. Subprocessors Kincode AI may engage subprocessors to support delivery of the services. Kincode AI remains responsible for the subprocessors it appoints and requires them to provide data protection commitments appropriate to the processing they perform. Data subject requests and assistance Taking into account the nature of the processing, Kincode AI will provide reasonable assistance to help the customer respond to requests from data subjects and meet its obligations under applicable Data Protection Laws. Requests should be sent to the customer, unless the parties agree that Kincode AI will respond directly. Security incidents Kincode AI will notify the customer without undue delay after becoming aware of a security incident affecting Customer Data and will provide reasonable information and cooperation to support the customer’s assessment and notification obligations. Deletion and return of data At the customer’s choice, Kincode AI will delete or return Customer Data after the end of the services, unless applicable law requires continued retention. Data retained for legal or security purposes remains protected under this DPA. Contacting us For questions about this DPA or Kincode AI’s data processing practices, contact us at compliance@kincode.ai or visit the Kincode AI Trust Centre.