Data Processing Addendum

This addendum forms part of the Terms of Service and applies where Keel Automation LLC processes personal data on behalf of Customer. Customer is the person who owns a personal account, or the company that owns a company account.

Roles

Customer is the controller of personal data submitted to the Service. Keel is a processor acting on Customer's documented instructions, which consist of the Terms, this addendum, and configuration made in the Service by Customer or, on a company account, by Customer's administrators.

Scope of processing

Subject matter: provision of SI agents, Cloud Computers on Plus and Premium, KeelDock on Premium, and connected tools. Duration: the term of the agreement. Nature and purpose: storing and processing content, memory, files, connection tokens, and usage records to operate the Service. Data subjects: Customer, company members, and any individuals whose data is submitted. Categories: identifiers, business contact data, and any personal data contained in content.

Keel's obligations

• Process personal data only on Customer's instructions.
• Ensure personnel with access are bound by confidentiality.
• Maintain the technical and organizational measures described on the Security page, including row-level access control, encryption in transit and at rest, short-lived credentials, isolated compute, and audit logging.
• Assist Customer with data subject requests, security assessments, and breach notifications; notify Customer without undue delay after becoming aware of a personal data breach.
• Delete or return personal data at the end of the agreement as described in the Privacy Policy.

Subprocessors

Customer authorizes the subprocessors listed in the Privacy Policy. Keel will give at least 30 days' notice of new subprocessors by email to administrators; Customer may object on reasonable grounds and, if unresolved, terminate the affected service.

International transfers

Data is stored in the United States. Where data originates in the EU, UK, or Switzerland, transfers are made under the Standard Contractual Clauses and UK Addendum, which are incorporated by reference.

Audit

On written request no more than once a year, Keel will make available information reasonably necessary to demonstrate compliance with this addendum.

Signed copies for procurement: legal@keelagents.ai.