Data Processing Agreement

Version: 1.2 | Effective Date: 14 October 2026 | Last Updated: 14 October 2026

This Data Processing Agreement ("DPA") forms part of the agreement under which Difinity Pty Ltd (ABN 82 686 692 759) provides the Services to the Customer.

1. Parties and legal identity

1.1 Parties

This DPA is between the customer identified in the applicable order form or enterprise agreement ("Customer") and Difinity Pty Ltd (ABN 82 686 692 759), with its registered office stated as Sydney, NSW, Australia ("Difinity").

1.2 Notices

Notices to Difinity under this DPA must be sent to privacy@difinity.ai, with a copy to legal@difinity.ai. Customer notices must be sent to the contact in the applicable order form or enterprise agreement.

2. Incorporation, scope and precedence

2.1 Incorporation

This DPA applies when the Customer uses the Services to process Customer Personal Data and is incorporated into the applicable order form, enterprise agreement or the Terms of Service.

2.2 Precedence

If this DPA conflicts with another part of the agreement on personal data processing, this DPA prevails. Applicable Standard Contractual Clauses or another binding transfer instrument prevail for a Restricted Transfer to the extent of any conflict.

2.3 Related documents

The Privacy Policy describes processing for which Difinity acts as a controller. The current list of Services Sub-processors is published at /sub-processors.

3. Roles by activity

3.1 Customer role

The Customer is a controller of Customer Personal Data. If the Customer processes Customer Personal Data for another controller, the Customer is a processor and appoints Difinity as its sub-processor.

3.2 Difinity role

Difinity is a processor or sub-processor when it processes Customer Personal Data to provide the Services on the Customer's documented instructions.

3.3 Separate controller purposes

Difinity acts as a separate controller for its own corporate account administration, security, billing, legal compliance, support relationship and website operations. Those activities are outside this DPA and are described in the Privacy Policy.

4. Definitions

4.1 Applicable Data Protection Law

"Applicable Data Protection Law" means privacy and data protection law that applies to the processing under this DPA, including the EU GDPR, UK GDPR and Australian Privacy Act 1988 (Cth), where applicable.

4.2 Customer Personal Data

"Customer Personal Data" means personal data or personal information contained in Customer Data that Difinity processes as a processor or sub-processor under the agreement.

4.3 Instructions

"Instructions" means the Customer's documented directions in the agreement, use-case and policy configuration, authorised API requests, connected-system configuration, support requests and other written directions consistent with the agreement.

4.4 Security Incident

"Security Incident" means an accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Customer Personal Data in Difinity's or a Sub-processor's custody. It excludes unsuccessful attempts that do not compromise Customer Personal Data.

4.5 Services

"Services" means the contracted Difinity.ai services, including Hub, the Platform API, Flow, the chat and agent workspace at chat.difinity.ai, and the tool gateway, as specified in the order form or enterprise agreement. The tool gateway is not reachable from the internet.

4.6 Sub-processor and Restricted Transfer

"Sub-processor" means a third party appointed by Difinity to process Customer Personal Data for the Services. "Restricted Transfer" means a transfer of Customer Personal Data that requires a recognised transfer mechanism under Applicable Data Protection Law.

5. Subject matter, duration, nature and purpose

5.1 Processing details

The subject matter, duration, nature, purpose, data categories and data subjects are set out in Annex 1.

5.2 Duration

This DPA applies for as long as Difinity processes Customer Personal Data under the agreement, including the return, deletion and legally required retention period described in clause 17 and Annex 1.

6. Documented instructions

6.1 Instruction limit

Difinity will process Customer Personal Data only on documented Instructions, including transfers, unless applicable law requires otherwise. If law requires processing outside the Instructions, Difinity will notify the Customer before processing unless the law prohibits notice. Enabling a provider's models for a use case in Hub is a documented Instruction to use that provider for the applicable model calls.

6.2 Unlawful instruction

Difinity will inform the Customer if, in its reasonable opinion, an Instruction infringes Applicable Data Protection Law. Difinity may suspend the affected processing while the parties resolve the issue.

6.3 Model training and benchmarks

Difinity will not use Customer Personal Data or Customer Content to train a general model or create an unrelated benchmark without the Customer's express written agreement.

6.4 Credentials

Provider keys and connector credentials are write-only through customer-facing interfaces. No endpoint available through customer-facing interfaces returns a stored credential.

7. Customer responsibilities

7.1 Lawful processing

The Customer is responsible for its lawful basis, required notices, data accuracy, and the legality of its Instructions and use of the Services.

7.2 Connected systems

The Customer must have authority to connect each provider, system and MCP server, grant each scope, and instruct actions using the relevant person or organisation credential.

7.3 Configuration

The Customer must configure use cases, policies, permissions, data handling and approval requirements appropriate to its activities. Difinity's controls do not replace the Customer's assessment of law, risk or required human oversight.

7.4 Sensitive data

The Customer must not submit special-category, sensitive, children's, health, biometric, criminal, regulated financial or similarly restricted data unless the applicable order form or enterprise agreement expressly permits that data and states the required safeguards.

8. Confidentiality and authorised personnel

8.1 Confidentiality

Difinity will limit access to Customer Personal Data to personnel who need it to perform the Services and who are bound by confidentiality duties. Difinity will maintain access-control and personnel offboarding processes appropriate to those duties.

8.2 Staff support access

Authorised Difinity staff have a separate, role-gated administration surface. They can administer organisations and people, billing, credits and plans, and view aggregate usage counts. They have no access through that surface to conversations, transcripts, run trails, agent definitions, prompts or uploaded files. Staff do not sign in as or impersonate one of an organisation's people. Staff can be added to an organisation only in a non-admin role. Difinity staff cannot be added as an administrator, and an added member holds only the permissions of the role given.

Every staff action on an organisation, including adding a staff member to it, is recorded in a privileged-access log. Each entry identifies the staff member and the organisation. The staff member is named in the entry's reason text. The entry for an add does not record the role given. The log cannot be updated or deleted through the application. It is deleted together with the organisation when the organisation is erased under clause 17. It is available to authorised Difinity staff for security and accountability review and is not currently available through Customer-facing interfaces.

8.3 Customer notice item

Difinity will notify the Customer of a material change to the staff access model in clause 8.2 through the agreement contact.

9. Security measures

9.1 Measures

Difinity will implement and maintain the technical and organisational measures in Annex 2, taking into account the nature, scope, context and purpose of processing and the risks to individuals.

9.2 No material reduction

Difinity may update the measures in Annex 2 if the update does not materially reduce the overall security of the Services.

9.3 Shared responsibility

The Customer remains responsible for its accounts, endpoint security, permissions, connected-system configuration and review of actions performed under its Instructions.

10. Sub-processors

10.1 General authorisation

The Customer gives general written authorisation for Difinity to appoint the Sub-processors listed in Annex 3 and at /sub-processors.

10.2 Changes and notice

Difinity will give at least 30 days' advance notice of a new or replacement Sub-processor that will process Customer Personal Data. Notice will be sent by email to the organisation's administrators and published at /sub-processors. A change in the country where an existing Sub-processor processes Customer Personal Data is treated as a new Sub-processor for this clause. Anyone can ask to be added to the notice list at privacy@difinity.ai.

10.3 Objection

The Customer may object during the notice period on reasonable data protection grounds. The parties will work in good faith on a commercially reasonable alternative. If no alternative is available, the Customer may terminate the affected Service without penalty, and Difinity will refund fees prepaid for the period after termination.

10.4 Flow-down and responsibility

Difinity will bind each Sub-processor by written data protection obligations that provide no less protection than the relevant obligations in this DPA. Difinity remains responsible for its Sub-processors to the extent required by Applicable Data Protection Law.

Where a Sub-processor listed in Annex 3 publishes no processor terms, Annex 3 says so, and the flow-down in this clause does not apply to that Sub-processor for Customer Personal Data that is not subject to the EU GDPR or UK GDPR. Difinity uses such a Sub-processor for Difinity-funded model calls only where the Customer has enabled that provider's models for a use case in Hub, which is the Customer's documented instruction to use it.

11. Customer-appointed third parties

11.1 Customer provider relationships

When the Customer supplies its own model-provider key or directly appoints a connected system, connector destination, OpenAPI connector or MCP server, that provider or destination is the Customer's own third-party relationship and is not appointed by Difinity as a Sub-processor for that interaction. This does not apply to Composio, which carries brokered connector calls and is a Sub-processor listed in Annex 3, or to Exa.

11.2 Customer instructions

The Customer instructs Difinity to disclose Customer Personal Data to a customer-appointed third party only as required by the configured request or action. Difinity remains responsible for the security controls it applies before that disclosure.

11.3 Credential boundary

An agent does not hold a credential. Every action on a connected system is proposed to the tool gateway, which decides, holds the credential and acts. The code sandbox is the exception described in clause A2.4.

12. International transfers

12.1 Hosting region

Difinity hosts the Platform in AWS Australia (Sydney, ap-southeast-2). That is the only live region today. Hosting in European Union (Frankfurt) and United States regions is available by arrangement: a dedicated deployment is set up when a customer signs. Model and connector calls can leave the hosting region. Where such a call carries Customer Personal Data to another country, including a call to Composio in the United States (us-east-1), it is a Restricted Transfer to which clause 12.2 applies. Hosting in Sydney does not mean that all Customer Personal Data stays in Australia. Some processing happens outside Australia: calls to model providers (see Annex 3), brokered connector calls to Composio in the United States, web search queries to Exa outside Australia, and payment data processed by Stripe. Difinity does not promise that Customer Personal Data stays in Australia unless an Order Form says so.

12.2 Restricted Transfers

The parties will not make a Restricted Transfer unless an adequacy decision, the applicable Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum, or another legally recognised safeguard applies.

12.3 Assessments and supplementary measures

Each party will provide reasonably requested information for a transfer impact or risk assessment. Difinity will implement supplementary measures identified as necessary and technically applicable to its processing.

12.4 Modules

For transfers subject to the EU Standard Contractual Clauses, Module 2 applies when the Customer is a controller and Module 3 applies when the Customer is a processor, unless the parties document another applicable module. Annex 4 gives the jurisdiction-specific structure and completion requirements.

13. Data-subject requests

13.1 Forwarding requests

Difinity will promptly notify the Customer if it receives a request from an individual concerning Customer Personal Data. Difinity will not respond except on the Customer's documented Instructions or as required by law.

13.2 Assistance

Taking into account the nature of processing, Difinity will provide reasonable technical and organisational assistance for access, correction, deletion, restriction, portability, objection and other applicable rights.

13.3 Identity and records

The Customer is responsible for verifying the requester and deciding how to respond. Difinity may request information reasonably required to identify the relevant Customer Personal Data and preserve security.

14. Security incidents

14.1 Notice

Difinity will notify the Customer without undue delay and no later than 72 hours after becoming aware of a Security Incident affecting Customer Personal Data in the custody of Difinity or a Sub-processor. The 72 hours is a maximum. Difinity will notify sooner where it can.

14.2 Contents and updates

The notice will describe, as information becomes available, the nature of the incident, affected data and individuals, likely consequences, mitigation and a contact point. Difinity will provide material updates and reasonable cooperation with the Customer's investigation and notification duties.

14.3 Mitigation

Difinity will take reasonable steps to contain, investigate and mitigate the Security Incident. Notice is not an admission of fault or liability.

14.4 Australian notifiable data breaches

Where the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act 1988 (Cth) applies to the Customer, the Customer is responsible for assessing whether a Security Incident is an eligible data breach and for notifying the Office of the Australian Information Commissioner and affected individuals, unless the parties agree in writing that Difinity will do so on the Customer's behalf. Where Difinity itself holds the information and the scheme applies to Difinity, Difinity will assess and notify as the scheme requires and will consult the Customer first unless the law requires otherwise. Difinity will give the Customer the information it reasonably needs to complete its assessment within the time the Act allows.

15. DPIAs and regulator consultation

15.1 Assistance

Taking into account the nature of processing and information available to Difinity, Difinity will provide reasonable assistance with data protection impact assessments and prior consultation required under Applicable Data Protection Law.

15.2 Customer decisions

The Customer remains responsible for deciding whether an assessment or consultation is required and for documenting its lawful basis, risks and safeguards.

16. Audit and compliance information

16.1 Information

Difinity will make available information reasonably necessary to demonstrate compliance with this DPA, including relevant security descriptions, questionnaire responses and available independent reports.

16.2 Audit

If that information is insufficient, the Customer or an independent auditor bound by confidentiality may conduct a proportionate audit at reasonable intervals and on reasonable notice. An audit must avoid exposing another customer's data, credentials, confidential information or security vulnerabilities.

16.3 Findings

Difinity will address a substantiated material non-conformity within a reasonable period agreed by the parties. Difinity does not claim a certification or regulatory determination that it has not independently obtained.

16.4 Compliance evidence boundary

Governed run records can contribute operational evidence to wider EU AI Act, ISO/IEC 42001, risk and audit processes. Difinity does not determine that an organisation or AI system is compliant, and it does not provide ISO/IEC 42001 certification.

17. Return, export, deletion and retention

17.1 End of Services

The Customer can use the self-service export during the Subscription Term. An organisation enters the Terminated state only when authorised Difinity staff set that state. Self-service export remains available for 90 days after that state is set. The export contains Transcripts and the Run Trail only. Transcripts are limited to conversations that the person running the export owns or has been given live access to; an administrator cannot export other people's private conversations. The Run Trail export covers the whole organisation. At the end of that window, Difinity's scheduled job deletes the organisation's database records, including conversations, messages, agents, knowledge and memory records, connector records, people, billing records and the privileged-access log. The job does not delete run trails. A run trail, and the sealed values behind its stand-ins, stays until its own retention period ends (7 years by default). The job does not remove everything else either. Difinity will remove files in storage and stored secrets by hand within 30 days of the end of the window, working from a recorded list. Difinity does not ask Stripe to delete the customer record, which Stripe keeps under its own terms. Linked accounts held by Composio and the tool gateway's own records of calls, including refused and automatically allowed calls, and its standing-approval memory, which hold tool arguments and have no automatic expiry, are not removed by the job; Difinity will remove them within 30 days of a request to privacy@difinity.ai. Login accounts held by Supabase are closed by the scheduled job. Difinity does not guarantee that the closed record is deleted; on request to privacy@difinity.ai, Difinity will ask Supabase to delete it. Chat attachments and artifacts expire after 28 days, even under a legal hold. Database backups containing erased data age out seven days later; older versions of stored files are removed by hand.

17.2 Customer-set periods and defaults

Each organisation sets its own run-trail and transcript retention periods. The run trail defaults to seven years and cannot be set below six months. Transcript retention defaults to while the organisation remains subscribed and can instead be set to a specified number of days. If the Customer does not choose a period, those defaults apply. Chat attachments and artifacts expire after 28 days. A parked agent run can no longer be read after seven days, or after one day past its approval deadline if that is later, and never after more than 15 days. Database backups are kept for seven days with point-in-time recovery. Memory notes and knowledge are kept until deleted. Agent shares by link have no expiry until revoked. See Annex 1, clause A1.9.

17.3 Transcript and trail

Difinity deletes run-trail records and transcripts when the applicable organisation-set period expires. Mapping rows expire with the run-trail records to which they relate. The transcript remains separate from the pseudonymised run trail and keeps the real values for the person's own conversation history until the transcript period expires.

17.4 Archive and erasure

The Services expose conversation archive, not conversation deletion. Transcript erasure follows the process in clause 17.1. The run trail stores redacted stand-ins while a separate encrypted mapping can make supported values revealable to an authorised person. The trail is pseudonymised, not anonymous, while that mapping exists. Mapping rows are deleted with the run-trail records to which they relate. Values masked with asterisks have no revealable mapping and cannot be revealed.

17.5 Backups and legal holds

A legal hold pauses scheduled expiry and erasure until the hold is lifted, except that chat attachments and artifacts expire after 28 days under their storage rule even while a hold applies. Data subject to another mandatory legal retention requirement may be kept only for the required period and restricted to that purpose. Backups containing erased data age out seven days after erasure.

17.6 Credentials

Difinity destroys a connector credential when it is revoked. On valid termination instructions, Difinity will revoke or destroy other stored provider credentials within its control. No endpoint available through customer-facing interfaces returns a stored value.

18. Government and law-enforcement demands

18.1 Review and notice

If Difinity receives a binding government or law-enforcement demand for Customer Personal Data, it will review the demand and notify the Customer before disclosure unless prohibited by law.

18.2 Minimum disclosure

Difinity will disclose only the minimum data legally required and will challenge an overbroad or unlawful demand where reasonable grounds and lawful means exist.

19. Records and regulatory cooperation

19.1 Processing records

Difinity will maintain records of processing required of a processor under Applicable Data Protection Law and provide information reasonably required for the Customer's corresponding records.

19.2 Regulator cooperation

Difinity will cooperate with a competent regulator as required by law and will provide the Customer reasonable assistance with a regulator inquiry concerning processing under this DPA.

19.3 Contacts

The privacy contact for this DPA is privacy@difinity.ai. Any representative or data-protection-officer details required by applicable law will be stated in the Privacy Policy.

20. Liability and indemnity

20.1 Agreement terms

Liability and indemnity arising under this DPA are governed by the limitations, exclusions and indemnities in the Terms of Service, applicable order form or enterprise agreement.

20.2 Mandatory rights

Nothing in this DPA limits a data subject's rights, a regulator's powers, liability under binding Standard Contractual Clauses, or rights and liabilities that cannot lawfully be limited or excluded.

21. Term, survival and changes

21.1 Term and survival

This DPA begins when it becomes binding under clause 22 and continues while Difinity processes Customer Personal Data. Confidentiality, return, deletion, retained-data protection, audit and transfer obligations survive for as long as relevant Customer Personal Data remains.

21.2 Changes

Difinity may update this DPA to reflect law, regulator guidance, Services or security changes. Difinity will give advance notice of a material change and will not materially reduce the protection of Customer Personal Data during a current order term without the Customer's agreement or a legal requirement.

22. Execution

22.1 Binding effect

This DPA becomes binding (a) when it is incorporated into an executed order form or enterprise agreement, or signed by authorised representatives of both parties, or (b) for a self-serve plan, when the Customer accepts the Terms of Service, which incorporate this DPA under clauses 8.2 and 16.1 of the Terms. Publication at /dpa alone does not create an agreement.

22.2 Counterparts and electronic signature

The parties may execute this DPA in counterparts and by electronic signature where permitted by law. Each counterpart forms one instrument with the others.

Annex 1. Processing details

A1.1 Subject matter and duration

Difinity processes Customer Personal Data to provide the contracted Services for the period described in clauses 5 and 17.

A1.2 Nature and purpose

Processing may include collection, transmission, storage, organisation, retrieval, detection and replacement of personal information, model inference, response delivery, agent and tool execution, approval handling, evidence recording, metering, billing, support, return and deletion.

A1.3 Data subjects

Data subjects may include Customer administrators, personnel, contractors and application end users; people identified in prompts, files, transcripts, model outputs, tool arguments, tool results and connected systems; and Customer contacts.

A1.4 Data categories

Customer Personal Data may include identifiers and contact details; account, authentication and session data; prompts, responses and transcripts; attachments and extracted content; agent memory notes and knowledge files; web search queries; agent, use-case and policy configuration; tool arguments and results; connected-system records; credential references; approvals; a redaction map; run-trail evidence; support records; and usage, invoice and billing data.

A1.5 Sensitive data

Sensitive or special-category data is not approved by default. The Customer may provide it only where the order form or enterprise agreement expressly identifies the data, purpose, lawful basis and safeguards.

A1.6 Frequency

Processing occurs when the Customer, its authorised people or its applications use or administer the Services, and during scheduled storage, backup, billing, support and deletion operations.

A1.7 Hosting and retention

The organisation's AWS hosting region is Australia (Sydney). Other regions are available by arrangement, with a dedicated deployment set up when a customer signs, as described in clause 12.1. Authentication data is processed in the same region as the organisation's hosting region. Model and connector calls can leave the hosting region.

Each organisation sets its own run-trail and transcript retention periods. The run trail defaults to seven years and cannot be set below six months. Transcript retention defaults to while the organisation remains subscribed and can instead be set to a specified number of days. If the Customer does not choose a period, those defaults apply. Data is deleted when its applicable period expires. Mapping rows expire with their related run-trail records. A legal hold pauses scheduled expiry and erasure until the hold is lifted.

Chat attachments and artifacts expire after 28 days, even under a legal hold. A parked agent run can no longer be read after seven days, or after one day past its approval deadline if that is later, and never after more than 15 days. Database backups are kept for seven days with point-in-time recovery. The Customer can use the self-service export during the Subscription Term. An organisation enters the Terminated state only when authorised Difinity staff set that state. Self-service export remains available for 90 days after that state is set. At the end of that window, Difinity's scheduled job deletes the organisation's database records, including conversations, messages, agents, knowledge and memory records, connector records, people, billing records and the privileged-access log. The job does not delete run trails. A run trail, and the sealed values behind its stand-ins, stays until its own retention period ends (7 years by default). The job does not remove everything else either. Difinity will remove files in storage and stored secrets by hand within 30 days of the end of the window, working from a recorded list. Difinity does not ask Stripe to delete the customer record, which Stripe keeps under its own terms. Linked accounts held by Composio and the tool gateway's own records of calls, including refused and automatically allowed calls, and its standing-approval memory, which hold tool arguments and have no automatic expiry, are not removed by the job; Difinity will remove them within 30 days of a request to privacy@difinity.ai. Login accounts held by Supabase are closed by the scheduled job. Difinity does not guarantee that the closed record is deleted; on request to privacy@difinity.ai, Difinity will ask Supabase to delete it. Chat attachments and artifacts expire after 28 days, even under a legal hold. Database backups containing erased data age out seven days later; older versions of stored files are removed by hand.

A1.8 Return and export

The self-service export contains Transcripts and the Run Trail. Transcripts are limited to conversations that the person running the export owns or has been given live access to; an administrator cannot export other people's private conversations. The Run Trail export covers the whole organisation. It does not contain agent definitions, knowledge files, memory or the tool gateway's records. Return and self-service export use formats and methods supported by the Services or otherwise reasonably agreed in writing. Individual attached files can be downloaded by their owner, one file at a time until they expire after 28 days.

A1.9 Agent features and what they keep

Annex 2. Technical and organisational measures

A2.1 Organisation isolation and staff access

Platform data is separated by organisation through row-level security. Authorised Difinity staff use a separate, role-gated administration surface to administer organisations and people, billing, credits and plans, and to view aggregate usage counts. They have no access through that surface to conversations, transcripts, run trails, agent definitions, prompts or uploaded files. Staff do not sign in as or impersonate one of an organisation's people.

Staff can be added to an organisation only in a non-admin role. Every staff action on an organisation, including an add, is recorded in a privileged-access log that identifies the staff member and organisation. Update and delete operations are not available through the application. The log is deleted together with the organisation when the organisation is erased. The log is available to authorised Difinity staff and is not currently available through Customer-facing interfaces.

A2.2 Storage protection

Platform data is stored in Aurora PostgreSQL 16.14 in private subnets and encrypted at rest with an AWS KMS key managed by Difinity. Database connections require SSL. Backups and point-in-time recovery are kept for 7 days.

A2.3 Credential protection

Provider keys and the credentials of connectors that Difinity connects directly are held as write-only credentials. For apps connected through the Composio broker, Composio holds the linked account and its tokens in the United States (us-east-1), and API keys entered for those apps go to Composio and are not stored by Difinity. Credentials remain write-only through customer-facing interfaces. No endpoint available through customer-facing interfaces returns a stored credential.

A2.4 Tool boundary

An agent holds no credential. Every action on a connected system is proposed to the tool gateway, which decides, holds the credential and acts.

There is one other way out. An agent's code sandbox has no Difinity credentials and no durable storage. Its internet setting is chosen per agent version. The default is no internet. A builder can instead choose a listed-websites-only mode (not yet available in production), or choose "Full internet", in which case code in the sandbox can send data to any website. Even with no internet, sandbox code may still reach AWS service addresses in Sydney. Files leave the sandbox only when the agent shares them as artifacts.

A2.5 Personal-information boundary

The generation model works on replaced text. This applies to generation models only. It does not apply to: the text of uploaded knowledge files, which is embedded as uploaded by Amazon Titan on AWS Bedrock in Sydney; the search copy of a memory note, which has only common personal details replaced; compliance drafting, which sends the original context to a Difinity-hosted model on AWS Bedrock; web search queries sent to Exa, which are sent as written; the reviewers, injection screen and content scan in the tool gateway, which see real values; the tool gateway's stored call arguments; knowledge questions and connected-source excerpts, which are embedded as written; code run in the sandbox, which works on restored real values; and brokered connector calls to Composio, which carry real values. Real values are restored only in the last step before an action leaves through the tool gateway. An action waiting for approval shows the restored form, which is the form approved and executed.

A tool result is checked for personal information before the generation model reads it. A result that cannot be checked, or that fails the check, is withheld. The run continues without it.

Where detection and replacement are enabled, the run trail stores the redacted stand-ins used during the run, not the original detected personal values, in recorded messages, model output, tool-call arguments and results, and policy reasons. The separate stand-in-to-original mapping is envelope-encrypted: a data key encrypts the values and one Platform AWS KMS key, configured for automatic rotation, protects the data key.

The run trail is pseudonymised, not anonymous, while a revealable mapping exists. Only a person with the PII:view permission can ask the server to reveal a mapped value, and every reveal is recorded. Values masked with asterisks have no revealable mapping and cannot be revealed. If the Customer turns personal-information detection off, the run trail stores the raw text and labels the run accordingly. The transcript remains separate and keeps the real values for the person's own conversation history.

A2.6 Action authority and evidence

An agent's authority is the intersection of the approved version's bindings, the caller's entitlements and the use case's permissions.

The run trail is append-only evidence. It is separate from the Configuration Log and the transcript.

A2.7 File and temporary-state controls

A chat attachment is limited to 25 MB and kept for 28 days. A parked agent run can no longer be read after 7 days, or after one day past its approval deadline if that is later, and never more than 15 days. Logs are described in clause A2.9.

A2.8 Review and change control

Difinity reviews material changes to these measures against the no-material-reduction obligation in clause 9.2. Security measures supplied by a Sub-processor remain subject to the applicable vendor agreement and Difinity's Sub-processor review.

A2.9 Operational logs

Difinity's application and gateway logs hold metadata only, such as ids, timing, status and error types, not customer content.

Annex 3. Services Sub-processors

A3.1 Conditions

The list below sets out the Services Sub-processors authorised under clause 10. Model providers are conditional Sub-processors only when Difinity funds the model call. If the Customer supplies its own provider key, the provider is the Customer's own provider relationship for that call.

Amazon Web Services Australia Pty Ltd

• Service and purpose: AWS, including Aurora, S3, Secrets Manager and Bedrock: hosting, storage, secret storage and Difinity-hosted model processing
• Customer personal data: Service data, stored content, credentials and model inputs and outputs as applicable
• Data subjects: Customer administrators, authorised people, application end users and people represented in Customer content
• Processing location: Australia (Sydney). Other AWS regions are available by arrangement, with a dedicated deployment set up when a customer signs. Model and connector calls can leave the hosting region
• Transfer mechanism: EU Standard Contractual Clauses adopted in June 2021, UK Addendum and Swiss addendum, as applicable
• Appointment date: Before 2 September 2026
• Privacy, security and processor terms: AWS DPA; AWS sub-processors; Bedrock privacy
• Customer notice: privacy@difinity.ai

Supabase Pte. Ltd.

• Service and purpose: Supabase: authentication and session services
• Customer personal data: Account identifiers, authentication data, session data and minimal profile claims
• Data subjects: Customer administrators and authorised people
• Processing location: in the same region as the organisation's hosting region: Australia (Sydney), or another region where one is agreed
• Transfer mechanism: EU Standard Contractual Clauses Module 2 or 3, UK Addendum and Swiss addendum, as applicable
• Appointment date: Before 2 September 2026
• Privacy, security and processor terms: Supabase DPA; Supabase sub-processors; Supabase security
• Customer notice: privacy@difinity.ai

Stripe Payments Australia Pty Ltd

• Service and purpose: Stripe and Stripe affiliates under Stripe's Data Processing Agreement: card payments, billing and invoicing
• Customer personal data: Customer contact, billing, invoice and payment-related data
• Data subjects: Customer billing contacts and authorised administrators
• Processing location: Multiple locations; Stripe does not publish one fixed processing region for the Services
• Transfer mechanism: EEA Standard Contractual Clauses Modules 1 and 2 and UK International Data Transfer Addendum, as applicable
• Appointment date: Before 2 September 2026
• Privacy, security and processor terms: Stripe DPA; Stripe service providers; Stripe security
• Customer notice: privacy@difinity.ai

OpenAI OpCo, LLC

• Service and purpose: OpenAI: conditional model inference for Difinity-funded calls
• Customer personal data: Model input, output and technical request metadata
• Data subjects: People represented in model input or output
• Processing location: Vendor-selected locations unless data residency is configured; available residency regions include Australia, the United States and Europe, while system data may be processed elsewhere
• Transfer mechanism: EU Standard Contractual Clauses for EEA and Swiss data and the UK Addendum for UK data; APP 8 reasonable steps apply to Difinity's disclosures from Australia
• Appointment date: Before 2 September 2026
• Privacy, security and processor terms: OpenAI DPA; OpenAI sub-processors; OpenAI API data controls
• Customer notice: privacy@difinity.ai

Anthropic, PBC

• Service and purpose: Anthropic: conditional model inference for Difinity-funded calls
• Customer personal data: Model input, output and technical request metadata
• Data subjects: People represented in model input or output
• Processing location: No single default processing country or region is stated in Anthropic's published commercial terms
• Transfer mechanism: EU Standard Contractual Clauses Module 2 or 3, UK Addendum and Swiss addendum, as applicable
• Appointment date: Before 2 September 2026
• Privacy, security and processor terms: Anthropic DPA; Anthropic sub-processors; Anthropic retention
• Customer notice: privacy@difinity.ai

Google Australia Pty Ltd

• Service and purpose: Google: conditional model inference for Difinity-funded calls
• Customer personal data: Model input, output and technical request metadata
• Data subjects: People represented in model input or output
• Processing location: No fixed default region for the Gemini Developer API; data may be processed in countries where Google or its agents maintain facilities unless a region-pinned service is used
• Transfer mechanism: EU Standard Contractual Clauses for controller-to-processor or processor-to-processor transfers and the EU-US Data Privacy Framework, as applicable
• Appointment date: Before 2 September 2026
• Privacy, security and processor terms: Google processor terms; Google sub-processors; Gemini API data controls
• Customer notice: privacy@difinity.ai

SpaceXAI (formerly xAI), as named in its Data Processing Addendum effective 24 August 2026

• Service and purpose: xAI (Grok): conditional model inference for Difinity-funded calls
• Customer personal data: Model input, output and technical request metadata
• Data subjects: People represented in model input or output
• Processing location: United States and other countries
• Transfer mechanism: EU Standard Contractual Clauses and UK Addendum under the SpaceXAI DPA; APP 8 reasonable steps apply to Difinity's disclosures from Australia
• Appointment date: Before 2 September 2026
• Privacy, security and processor terms: SpaceXAI DPA; xAI API security
• Customer notice: privacy@difinity.ai

Composio (Sampark, Inc., trading as Composio)

• Service and purpose: Composio: broker for connector apps connected through the Composio catalogue. It carries brokered connector calls and holds the linked accounts and their tokens
• Customer personal data: Arguments and results of brokered connector calls, linked-account identifiers, and the OAuth tokens and API keys the broker holds for those accounts
• Data subjects: Customer administrators, authorised people and people represented in connected-system records
• Processing location: United States (AWS us-east-1), outside the hosting region
• Transfer mechanism: EU Standard Contractual Clauses (Modules 2 and 3) under the Composio Data Processing Addendum, as applicable; APP 8 reasonable steps apply to Difinity's disclosures from Australia
• Appointment date: 12 October 2026
• Privacy, security and processor terms: Composio DPA; Composio sub-processors
• Customer notice: privacy@difinity.ai

Exa (Exa Labs, Inc.)

• Service and purpose: Exa: the built-in web search and research tool. The tool is added to an agent version by its builder
• Customer personal data: The search query and the caller's country. Search queries may contain personal information. Difinity does not redact personal information from search queries, because doing so would stop the search returning correct results
• Data subjects: People mentioned in a search query
• Processing location: Outside Australia (United States, and possibly other countries). Exa Labs, Inc. is based in San Francisco, United States, and does not publish where it processes queries
• Transfer mechanism: EU Standard Contractual Clauses and UK Addendum under the Exa Data Processing Addendum, as applicable; APP 8 reasonable steps apply to Difinity's disclosures from Australia
• Appointment date: 12 October 2026
• Privacy, security and processor terms: Exa DPA; Exa privacy policy; Exa trust centre. How long Exa keeps queries is set by Exa's own terms
• Customer notice: privacy@difinity.ai

A3.2 Current list

The public version of this list and change notices are available at /sub-processors.

Annex 4. International transfer mechanisms

A4.1 European Economic Area

Where EU GDPR applies to a Restricted Transfer, the parties incorporate the European Commission Standard Contractual Clauses adopted by Implementing Decision (EU) 2021/914. Module 2 applies to controller-to-processor transfers and Module 3 applies to processor-to-processor transfers, as applicable. The order form or transfer schedule must complete the parties, competent authority, governing law, processing details, security measures and Sub-processor information. Where no order form or transfer schedule completes the Clauses: clause 7 (docking) applies; clause 9(a), Option 2 (general authorisation) applies with 30 days' notice under clause 10.2; clause 13, the supervisory authority of the Customer's establishment; clause 17, Option 1, the law of Ireland; clause 18(b), the courts of Ireland. The parties to the Clauses are Difinity, as identified in clause 1.1, and the Customer, as identified in its Hub organisation record and the record of its acceptance of the Terms; the contact details in those records apply. Annexes I.B, II and III of the Clauses are Annexes 1, 2 and 3 of this DPA.

A4.2 United Kingdom

Where UK GDPR applies to a Restricted Transfer, the parties will complete the UK International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses, as applicable, together with the required transfer risk assessment.

A4.3 Australia

Where the Australian Privacy Act applies and Customer Personal Data is sent to a recipient outside Australia, Difinity: (a) does so only as listed in Annex 3 or on the Customer's Instructions; (b) takes the steps that are reasonable in the circumstances before the disclosure to ensure the recipient does not breach the Australian Privacy Principles (other than APP 1) in relation to that data, including by binding each Sub-processor to written terms to that effect; and (c) will tell the Customer, on request, each recipient's name and country, or that the recipient publishes no country, so the Customer can meet its own APP 1 and APP 8 obligations. Difinity's liability under this clause is subject to clause 20.

A4.4 Other jurisdictions

For another jurisdiction, the parties will complete any mandatory local controller-processor terms or transfer instrument in the order form or a written addendum. Neither party may treat this Annex as replacing a mandatory local instrument.