Draft — pending counsel
Data processing addendum
Last updated — pending counsel
1. Scope and roles
You are the controller of your organisation's data; Praxis is the processor, acting on your documented instructions to provide the service. This is a pre-launch stub of the decided governance posture — final wording is prepared with counsel, and no warranties are made beyond the posture set out here.
2. Purpose of processing
Praxis processes your data only to provide the security-advisory service you have signed up for — running the advisor, maintaining your security-program records, and operating the application. We do not process it for any other purpose, and we do not sell it.
3. AI processing — zero retention, no training
Your data sent to the Praxis advisor is processed by Anthropic under two locked terms: zero data retention (prompts and completions are not retained beyond what is needed to return a response) and no training on API data (Anthropic does not use it to train its models). All AI usage runs through a single platform key, metered per organisation; there are no per-customer keys. Consent to this AI processing is recorded per organisation at onboarding, with a timestamp and policy version.
4. Sub-processors
Praxis engages a defined set of sub-processors to deliver the service, each handling a specific function (hosting, database, authentication, AI, email, error tracking, analytics). They are named in full — with what each one does — in the Trust Center. Anthropic, the AI sub-processor, operates under the zero-retention / no-training terms described above.
5. Retention and deletion
On offboarding, access is revoked immediately and your data is soft-deleted, then purged after a roughly 30-day window kept for accidental-cancellation recovery and a final export. We honour GDPR / CCPA deletion requests (support-assisted at launch). The full lifecycle is set out in the Praxis data retention & deletion policy.
6. Security and data-subject assistance
Access is role-scoped (RBAC), privileged and data-affecting actions — including consent and deletions — are recorded in an audit log, and we assist with data-subject requests as described in the retention & deletion policy. Technical and organisational measures are finalised with counsel before launch.
7. International transfers
Some sub-processors operate in the United States — notably Vercel (hosting and file storage) and Neon (database). Product analytics are hosted in the European Union. Where data moves across borders, transfers rely on the mechanisms required by applicable law (such as standard contractual clauses); the specific transfer mechanisms are confirmed with counsel before launch and will be stated in the final version.
8. Consent, changes, and contact
Two consent records are kept per organisation: acceptance of these terms and the Data Processing Addendum, and the explicit AI-processing acknowledgment described in Section 3 — each stamped with a timestamp and a policy version so records stay attributable to the posture actually accepted. We may update this addendum as the service evolves and will give reasonable notice of material changes. This is a pre-launch draft prepared by Praxis, not legal advice; questions and data-subject requests can be sent to the contact address published in the Trust Center.