Data processing addendum
Structure required
Section titled “Structure required”1. Definitions and scope
Section titled “1. Definitions and scope”- Counsel to draft.
2. Roles
Section titled “2. Roles”- The customer is the controller of customer-supplied data (rosters, threads, ICP text); Verdict is its processor.
3. Details of processing
Section titled “3. Details of processing”- Subject matter: answering named decisions for the customer’s agent.
- Duration: for the request; redacted request logs for 30 days; decisions and outcomes (which hold feature hashes, not text) for the life of the org plus 90 days.
- Categories of data and data subjects: counsel to draft from the API schemas.
4. Processor obligations
Section titled “4. Processor obligations”- Counsel to draft.
5. Subprocessors
Section titled “5. Subprocessors”- The list is on the subprocessors page. Counsel to draft the notice and objection mechanism.
6. Security measures
Section titled “6. Security measures”- Technical and organizational measures are described on the security overview page (encryption in transit, row-level tenant isolation, hashed keys, redacted logs, envelope-encrypted secrets, audit logging).
7. Personal data breach notification
Section titled “7. Personal data breach notification”- Customers are notified within 72 hours of a confirmed data incident.
8. Assistance with data subject requests
Section titled “8. Assistance with data subject requests”- Counsel to draft.
9. Deletion and return
Section titled “9. Deletion and return”- Org deletion completes within 30 days and is confirmed by email. Vault entries are deleted on removal and on org deletion.
10. Audits
Section titled “10. Audits”- Counsel to draft. SOC 2 readiness, not certification, in v1. Annual penetration test.
11. International transfers
Section titled “11. International transfers”- Counsel to draft. US only.