Your agreement

    Zitado Data Processing Agreement

    Our agreement for processing your organisation’s personal data, with instructions and annexes A–D.

    PolicyUpdated

    Version and document fingerprint

    1.0 · Standard agreement; customer acceptance must be documented separately

    SHA-256: 646d36a98be102ecf389899343ba35e70996385f069fbddabd1281cfd093d25b

    Subprocessors · Annex C

    Version: 1.0 · 19 October 2026 Document address: https://www.zitado.com/en/data-processing-agreement

    1. Parties and contractual basis

    This Data Processing Agreement ("DPA") is entered into between:

    Controller: The business, organisation or public authority subscribing to Zitado, whose legal name, address, registration number and authorised contracting party are recorded in its order/account information ("Customer").

    Processor: Camonda ApS (registered secondary name: ZELLERT ApS), Søndergade 3, 1., 7830 Vinderup, Denmark, Danish company registration number (CVR) 43532421, email info@zitado.com ("ZELLERT" or "Zitado").

    This DPA forms part of the agreement governing the use of Zitado and applies to personal data that ZELLERT processes on the Customer's behalf. It is intended to satisfy the requirements of Article 28(3) and (4) of Regulation (EU) 2016/679 (the "GDPR"). It is not an unmodified reproduction of standard contractual clauses approved by the Danish Data Protection Agency or the European Commission.

    This DPA takes effect when a person authorised to bind the Customer accepts it electronically or in writing. ZELLERT must retain evidence of the Customer's identity, the accepted document version, time and method of acceptance. Merely placing this DPA on a website does not establish its acceptance.

    An existing binding separate data processing agreement remains in place until a valid amendment or replacement is agreed. A change to the login flow or an internal customer status does not itself amend that agreement. Documented acceptance outside the platform may be recorded with a reference to the actual agreement and acceptance; it must not be represented as a new acceptance of this version.

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    2. Definitions and allocation of roles

    "Personal data", "processing", "controller", "processor", "subprocessor" and "personal data breach" have the meanings assigned by the GDPR.

    The Customer determines the purposes and essential means of processing personal data that it enters, uploads or manages in Zitado. ZELLERT processes such data under documented instructions and acts as a processor in that relationship.

    ZELLERT may act as an independent controller for its own customer relationship, subscription, billing, sales, security and statutory accounting activities. Those processing activities are outside ZELLERT's processor role under this DPA and are addressed in Zitado's privacy policy. Depending on the particular payment activity, Stripe may act as an independent controller and/or as a processor for ZELLERT. Stripe is not automatically a subprocessor for personal data held in the Customer's Ai governance records.

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    3. Subject matter, nature and purpose of processing

    Annex A specifies the subject matter, duration, personal data types, data subject categories, purposes and operations. Processing can involve records of employees and teams, Ai tools and use cases, training, usage rules, governance decisions, documents, assessments, reports and support to the extent they contain personal data.

    The optional Ai Policy Generator is described in Annex D. It is an optional function whose availability depends on the plan, trial and any add-ons. When used under the Customer’s documented instructions, limited inputs, potentially including personal data appearing in free-text fields, may be processed by OpenAI as a subprocessor, as detailed in Annexes C and D. Replacing known names with tokens does not in itself make all API input anonymous.

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    4. Customer instructions and responsibilities

    ZELLERT shall process personal data only on the Customer's documented instructions, including for transfers to third countries, unless processing is required by applicable EU or Member State law. In that case ZELLERT shall inform the Customer before processing, unless that law prohibits such notification on important grounds of public interest.

    The documented instructions consist of this DPA and its annexes, the agreed Zitado functionality and settings, actions of authorised Customer users, and separate written instructions accepted by ZELLERT. Instructions materially changing the service may require a separate agreement, but this cannot waive ZELLERT's statutory processor obligations.

    The Customer is responsible for establishing a lawful basis, giving appropriate notices to its employees and other data subjects, applying data minimisation, assigning appropriate access rights and ensuring that its intended use of Zitado is lawful.

    Use restriction: Zitado is not intended for national identification numbers (including Danish CPR numbers), criminal conviction or offence data, or special categories of data under GDPR Article 9 (such as health information, trade union membership, religious beliefs, or biometric data for uniquely identifying an individual). The Customer shall not enter such data into the service, including through free text, uploaded documents or the Ai Policy Generator. If such information is nevertheless received, ZELLERT must safeguard it and cooperate with the Customer regarding lawful restriction or deletion. The contractual restriction does not eliminate either party's GDPR duties.

    ZELLERT shall inform the Customer without undue delay if, in ZELLERT's opinion, an instruction infringes the GDPR or other applicable EU or Member State data protection law. ZELLERT may suspend the affected processing while legality is assessed, to the extent necessary.

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    5. Confidentiality and authorised personnel

    ZELLERT shall ensure that persons authorised to process personal data are bound by confidentiality obligations or an appropriate statutory duty of confidentiality. Access shall be granted on a need-to-know basis and revoked when no longer required. Staff and relevant contractors shall receive appropriate data protection and security instructions.

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    6. Technical and organisational security measures

    ZELLERT shall implement and maintain measures appropriate to the nature and risks of processing under GDPR Article 32. Annex B sets out minimum safeguards and verification items, including encryption in transit, appropriate encryption at rest, logical separation between customers, access control and roles, secret management, backups and restoration, security logging, incident handling, change management and supplier oversight.

    ZELLERT shall document the implemented measures. ZELLERT shall periodically evaluate the effectiveness of the measures, adjust them according to documented risks, and provide relevant evidence under clause 12.

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    7. Subprocessors

    The Customer grants general written authorisation for the subprocessors and processing purposes identified in Annex C in the version accepted by the Customer. A provider is included only for services in which it actually processes personal data on the Customer's behalf.

    ZELLERT shall enter into binding agreements imposing data protection obligations on subprocessors that are no less protective than those set out in this DPA and GDPR Article 28(4). ZELLERT remains fully liable to the Customer for the subprocessor's performance of its processor obligations.

    ZELLERT shall notify the Customer in writing of an intended addition or replacement of a subprocessor reasonably in advance of the change, and shall provide an opportunity to object on substantiated data protection grounds. Notice is 30 calendar days by email to the Customer’s registered contractual contact. If the Customer raises a justified objection, the parties shall discuss an appropriate alternative. If no adequate alternative is available, the Customer may terminate use of the affected service component under an agreed procedure without limiting mandatory rights.

    OpenAI is a conditional subprocessor. Use of an optional Ai function requires documented instructions from the Customer covering the particular module, its described input and the relevant provider and transfer documentation. Access through a subscription, trial, add-on or activation is not itself a processing instruction. An authorised user’s specific generation request may be carried out only within the instructions already agreed. OpenAI does not automatically receive all of the Customer’s data because this DPA includes this conditional approval.

    ZELLERT records provider notices and assesses the change’s effect on the Customer’s information and agreement. The customer notice must identify the affected subprocessor, processing, expected start date and opportunity for a reasoned objection. A provider’s shorter notice does not shorten the Customer’s agreed notice period or right to object. If the change cannot be implemented consistently with the Customer’s agreement, ZELLERT must arrange an appropriate alternative or end the affected processing before the change takes effect for the Customer. Separate customer agreements with different notice requirements continue to apply. Questions and objections may be sent to info@zitado.com.

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    8. Processing locations and international transfers

    The fact that Zitado's primary Supabase database is located in the EU does not mean that every supplier, email service, log, support operation, security service or API call processes data exclusively within the EU/EEA.

    ZELLERT shall make or permit transfers outside the EU/EEA only in accordance with GDPR Chapter V and documented Customer instructions. Where applicable, a valid mechanism shall be used, such as an adequacy decision or the European Commission's international-transfer SCCs together with relevant supplementary measures. International-transfer SCCs under Chapter V are not interchangeable with an Article 28 DPA.

    ZELLERT shall maintain an up-to-date register of relevant recipients, data categories, processing locations, third-country access and transfer safeguards and make this information available to the Customer.

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    9. Data subject rights

    Taking into account the nature of processing and the information available, ZELLERT shall assist the Customer with requests concerning access, rectification, erasure, restriction, portability, objection and other applicable GDPR Chapter III rights, using appropriate technical and organisational measures to the extent possible.

    If ZELLERT receives a request directly in relation to processing controlled by the Customer, it shall normally forward that request to the Customer's designated contact without undue delay unless the law requires otherwise. ZELLERT shall not answer on the Customer's behalf without instructions. Requests concerning ZELLERT's independent controller processing shall be handled separately by ZELLERT.

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    10. Assistance with compliance and assessments

    ZELLERT shall reasonably assist the Customer with available information to comply with GDPR Articles 32-36, including security, data protection impact assessments (DPIAs), any prior consultation and transfer assessments. Assistance is limited by the nature of processing and the information available to ZELLERT and does not shift the Customer's controller responsibilities to ZELLERT.

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    11. Personal data breaches

    Upon becoming aware of a personal data breach involving data processed on the Customer's behalf, ZELLERT shall notify the Customer without undue delay and provide available information about the nature of the breach, affected persons and data categories, likely consequences, mitigation steps and an appropriate contact point. Further information may follow in phases where not immediately available.

    ZELLERT shall assist with investigation, containment, documentation and the information needed for the Customer to evaluate notification to regulators and individuals. The Controller's potential 72-hour supervisory-authority notification deadline must not be confused with a general 72-hour period for the Processor's notification; the latter is required without undue delay.

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    12. Information, audit and inspection

    ZELLERT shall make available the information necessary to demonstrate compliance with GDPR Article 28 and allow for and contribute to audits, including inspections, conducted by the Customer or an independent auditor mandated by the Customer.

    The parties may first consider relevant security documents, assessment results, processing records and written control evidence. A documentary review does not categorically replace the right to further appropriate audits. Audit activities shall be proportionate and preserve confidentiality, other customers' data and continuity of service. Urgent situations, including serious incidents, shall be addressed separately.

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    13. Return, export, deletion and backups

    Following termination of the service, the Customer shall choose whether personal data processed on its behalf should be returned or deleted, unless retention is required by applicable EU or Member State law. ZELLERT shall delete existing copies in accordance with lawful Customer instructions, subject to mandatory retention and a documented backup cycle.

    In line with Zitado's current terms, the Customer normally has 60 calendar days following termination to retrieve its exportable data. In an agreed provider-switching scenario, the retrieval period runs from the end of the agreed transition. Unless the Customer has provided another lawful instruction, the relevant Customer data shall then be erased or anonymised, subject to documented exceptions for legal retention obligations, legal claims/disputes, an expressly agreed longer period and temporary residual backup copies deleted or overwritten under an approved cycle.

    The following periods apply to information processed on the Customer's behalf, subject to earlier lawful deletion instructions and any stricter separate customer agreement:

    ProcessingDeadline
    Active-system deletion after the export periodAs soon as possible and within 7 days after the 60-calendar-day period ends.
    Expired trial without conversionReactivation for 60 calendar days from trial expiry, followed by active-system deletion within 7 days. An ordinary login does not restart the period.
    BackupsA rolling cycle of at most 30 days. Residual copies are deleted or overwritten within 30 days after active-system deletion. Previously deleted data is removed again on restoration before ordinary use.
    Support correspondence / support attachments12 months / at most 90 days after case closure, respectively, or earlier where the relevant customer data must be deleted under the Customer's instructions or agreement.
    System emailsMessage contents for at most 30 days after sending and necessary delivery metadata for at most 90 days.
    Operational and error logs / security and access logsAt most 30 days / 90 days from the event, respectively. Evidence of a specific incident may be retained separately with documented necessity and review.

    The normal process can therefore take at most 97 days from the start of the 60-day export period until the last residual backup copy expires, where the full export, deletion and backup periods are used. The start date for an agreed provider switch is described above. This is not a minimum period and does not extend stricter deadlines already agreed. A lawful retention exception covers only necessary, specifically limited information. A user's continued membership of another organisation must be handled separately.

    A separately agreed overall deletion deadline covers all relevant recoverable copies of the Customer’s information. ZELLERT must plan return, active deletion and expiry or removal of backup and provider copies within that deadline. The Customer’s agreed export access must not be shortened unilaterally to make the deletion schedule fit. A shorter export period or other change to the exit arrangements requires the Customer’s agreement. Support, emails and logs containing information processed on the Customer’s behalf must be included in the plan; a generally longer retention period must not override a stricter customer agreement. Only specifically identified information with an independent lawful retention basis may be excepted. On completion, ZELLERT must be able to explain the deletion performed and any remaining information, its basis and its deadline.

    Return and deletion are handled through a documented procedure covering each relevant data category. For each case, ZELLERT records the Customer’s instructions, export access, affected systems and copies, and applicable deadlines. An export may be provided manually to a verified, authorised recipient; a payment restriction must not itself prevent the Customer’s agreed export access. Deletion of active information and recoverable residual copies is documented separately. A shorter customer-specific deadline takes precedence over general retention periods.

    Where the Customer’s agreement permits both data return and reactivation during a winding-down period, both options must remain available throughout the agreed period. ZELLERT may use a separately protected termination copy when its completeness, usable export format and ability to restore the data have been checked before active information is removed. The copy and its key copies must not extend the Customer’s overall deletion deadline. Other affected copies must be retired in time, and the termination copy and relevant key copies must be removed by the deadline. This storage arrangement does not amend the Customer’s agreed rights.

    On request, ZELLERT shall provide deletion evidence or explain any remaining data and the lawful reasons for retaining them. Removal of an organisation account must not be treated as evidence that all copies at subprocessors have been deleted; applicable downstream deletion obligations must be completed.

    ZELLERT has established daily backups of the database and uploaded files through a dedicated server hosted by Hetzner in Germany. Each copy is encrypted before storage in a Cloudflare R2 bucket with EU jurisdiction. This separate arrangement is configured for no more than seven days of history followed by physical repository cleanup. Backup, health checks, cleanup and alerts are enabled, and a full restoration of an actual copy has been tested in an isolated environment. A separate deletion journal must be applied during restoration before data returns to ordinary use; the journal does not itself erase recoverable copies. Other providers’ copies remain subject to their documented cycles and the applicable contractual deadlines. A stricter overall customer deadline takes precedence and must not be extended by the standard backup cycle.

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    14. Ai Policy Generator and other automation

    Annex D describes the optional policy generator for internal and external policy drafts. Both variants use section-based input and OpenAI for language refinement. The Customer’s documented instructions must be in place before the affected processing. This annex does not automatically authorise other generators.

    ZELLERT shall not use Customer personal data to train its own or third parties' general-purpose Ai models. ZELLERT shall not opt in to training-data sharing with OpenAI for Customer content. The model provider's safety logs, API retention and processing locations must be described in accordance with the actual agreement and configuration; store: false is not evidence of zero retention.

    The document generator sends broader organisation, tool and use-case context to OpenAI and is not covered by the policy generator’s data-minimisation description in Annex D. The training generator uses a separate, bounded basis and does not send employees’ answers, scores, profiles or training history as model input. Both functions require their own documented instructions and the relevant provider and transfer assessment. Plan access, activation or use of the policy generator does not extend those instructions. A Customer’s agreed restriction on OpenAI processing must be respected regardless of which functions are technically available.

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    15. Public-authority access requests

    ZELLERT shall notify the Customer of legally binding public-authority demands for Customer personal data to the extent permitted by law and shall assess the lawfulness and necessity of any disclosure. ZELLERT shall not provide broader access than legally required. Nothing limits statutory rights of data subjects or regulators.

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    16. Duration, amendments and termination

    This DPA remains in effect for as long as ZELLERT processes personal data on the Customer's behalf, including any lawful winding-down and deletion period. ZELLERT may not unilaterally reduce statutory GDPR protections by changing a document version. Material amendments shall be notified and validly made binding, and where a new instruction or agreement is required, that approval must be obtained before affected processing changes.

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    17. Liability, precedence and governing law

    Neither party's statutory liability under the GDPR, including Article 82, may be waived contrary to mandatory law. Commercial provisions on liability, charges and breach follow the applicable terms of service insofar as consistent with the GDPR and this DPA.

    For matters concerning processing of personal data on the Customer's behalf, this DPA and any mandatory international-transfer clauses prevail over the general terms in the event of conflict. Danish law applies subject to mandatory EU law and the authority of competent supervisory bodies.

    The Danish text is the primary contractual language. In the event of inconsistency between the Danish and English versions, the Danish version prevails unless expressly agreed otherwise.

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    18. Signature or electronic acceptance

    Controller (Customer)Processor
    Identified by legal name and company registration number in the documented agreement/acceptance recordCamonda ApS (registered secondary name: ZELLERT ApS), Danish CVR 43532421
    Authorised representative, acceptance date/time and accepted DPA/annex versions are recorded in the Customer's electronic acceptance evidence or signatureinfo@zitado.com

    For electronic acceptance, an immutable copy of the DPA, including its accepted annex versions, is linked to the Customer's acceptance record. For wet-ink signature, equivalent identifying information must be added to the signed agreement before execution.


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    Annex A - Processing instructions and description

    ItemDescription
    Subject matterProvision and support of Zitado as a B2B SaaS platform for Ai governance, documentation, staff training and compliance work
    DurationSubscription term plus agreed lawful data export, termination and deletion period
    PurposesRecording, organising, storing, displaying, managing access, reporting, generating documents, sending notices and providing support on Customer instructions
    Processing operationsCollection from Customer users, structuring, storage, searches, updates, rule-based evaluation, display, export, deletion and, where instructed by the Customer, limited API processing
    Categories of data subjectsEmployees, managers, administrators, external consultants and other persons the Customer lawfully records in the service
    Categories of personal dataName, work email, role, team, user ID, associations with Ai tools/use cases, training assignments and results, approvals, tasks, notes, document references, file metadata, relevant support data and security events
    Excluded categoriesNational ID/CPR numbers, GDPR Article 9 data, Article 10 criminal offence data, and other especially sensitive information under clause 4
    SourcesAuthorised Customer users, Customer inputs and uploads, and activities generated within the agreed service
    Potential recipientsAuthorised persons at the Customer, Zitado personnel with a work-based need, approved Annex C subprocessors, and parties the Customer instructs disclosure to (e.g. through a Trust Center)
    Optional moduleAi Policy Generator: Annex D; not automatically used by all Customers
    RetentionDeadlines and winding down under clause 13 and Annex B; a stricter separate Customer agreement takes precedence

    Customer users could accidentally enter additional personal data in free text or files. This possibility does not expand authorised processing purposes; ZELLERT must still safeguard and deal appropriately with any information it actually processes.

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    Annex B - Minimum technical and organisational measures

    ZELLERT shall maintain the following minimum measures, assess their effectiveness and document them in relation to the risks of the processing.

    1. Identity and access: Unique accounts, role-based permissions, appropriate multifactor protection for privileged access, timely deprovisioning and periodic review of elevated access.
    2. Customer isolation: Logical tenant separation and verified database/storage controls (including relevant Supabase row-level security policies) that prevent cross-customer access.
    3. Encryption: TLS/HTTPS in transit, appropriate encryption at rest, and secure handling of keys and credentials. No privileged API secret in browser bundles.
    4. Logging: Security-relevant event and permission logging, restricted access and documented retention; avoid unnecessary Customer content in diagnostic and application logs.
    5. Availability and recovery: Daily encrypted database and file backups, restricted access, documented key recovery arrangements and application of the deletion journal during restoration. An actual full copy has been restored in an isolated environment with checks of database contents, permissions and file contents. Backup failures and missing health reports are monitored, and a controlled alert has been delivered to the person responsible for operations. Copies expire according to the documented cycle and applicable customer agreements.
    6. Development and change management: Code reviews, testing, vulnerability management, least-privilege access to production and suitable separation of development and production.
    7. Incident management: Detection, internal escalation, containment, documentation and Customer notification without undue delay.
    8. People and suppliers: Confidentiality, need-to-know access, relevant security training and appropriate contractual supplier controls.
    9. Ai module: An authorised user initiates processing under the Customer’s instructions. In the policy generator, the browser replaces known identifying information with placeholders before transfer to the model. The substitution list and document basis are sent separately to Zitado’s server; they are not included as such in the model’s section input. The server validates the model input, restores known names in the result and saves a draft. Free text may still contain personal data. The document and training generators have separate input boundaries.
    10. Minimisation and deletion: Return/deletion follows Customer instructions and the approved deletion/backup process. Expiry of an access token is not proof that stored data was erased.
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    Annex C - Approved subprocessors and role register

    The list covers the stated services insofar as they process information on the Customer’s behalf and in the version accepted by the Customer. OpenAI is conditional on the separate instructions described in clauses 7 and 14 and Annex D. Suppliers’ differing retention periods do not amend ZELLERT’s obligations under clause 13 or a stricter Customer agreement.

    SupplierService and potential Customer dataRole/statusLocation and transfer mechanism
    Supabase Pte. Ltd.Auth, database, Storage and server functionsSubprocessor for Customer data; standard DPA incorporated in termsPrimary database in Frankfurt, EU. DPA includes SCC safeguards for relevant third-country transfers. Pro daily database backups have seven-day retention; uploaded file bytes are included in ZELLERT’s separate backup arrangement using Hetzner and Cloudflare R2.
    Vercel Inc.Hosting, requests and relevant IP/operational logsSubprocessor insofar as Customer data are processed; otherwise ZELLERT's own supplier. Standard DPA incorporated in termsHosting region Frankfurt (fra1); Observability Plus: 30-day runtime-log history. DPA includes SCC safeguards; not EU-only.
    Plus Five Five, Inc. (Resend)Transactional/system email, recipients, content and delivery dataSubprocessor for email on the Customer's behalf; standard DPA incorporated in termsIrish sending region; storage in the USA. DPA includes SCCs. Pro email/log history 30 days, supplier backups seven days, remaining Customer data up to 90 days after account closure according to the supplier.
    OpenAI Ireland Ltd.Optional Ai functions: policy rewriting, training drafts and separate document generation with broader contextConditional subprocessor for enabled and used features. Annex D covers policy processing; other generators require separate instructions. Standard DPA incorporated in supplier termsGlobal standard retention; no documented ZDR/EU-only agreement. Abuse monitoring generally up to 30 days subject to supplier exceptions; Responses uses store: false. All three optional sharing settings are off. DPA includes SCC safeguards.
    Hetzner Online GmbHCoordination and temporary processing of database and file backups on a dedicated serverSubprocessor for the separate backup arrangement. DPA established for Camonda ApS and the backup serviceFalkenstein, Germany. Private temporary staging in memory; encryption before transfer to R2. Daily backup, key recovery arrangements and isolated restoration have been established and tested. The Customer’s contractual basis and any stricter deletion deadlines continue to apply.
    Cloudflare, Inc. (R2)Storage of encrypted backup copiesSubprocessor for the separate backup arrangement; this role is distinct from TurnstilePrivate bucket with EU jurisdiction. This does not mean that all account, support and security processing takes place in the EU/EEA. Daily backup is enabled with seven-day snapshot retention and physical repository cleanup. An actual database and file copy has been restored and checked in an isolated environment. The Customer’s stricter overall deletion deadlines take precedence.

    Scope distinction: Stripe handles ZELLERT's billing relationship and must be included as appropriate in ZELLERT's own records and privacy notice. Depending on the service, Stripe can be a processor or an independent controller. It is not automatically a subprocessor for Customers' Ai governance content. Website tracking providers such as Google, Ahrefs and Meta must be assessed under the relevant cookies, analytics and marketing activities, rather than automatically inserted into this Customer-content subprocessor schedule.

    ZELLERT shall maintain the current approved list, notification mechanism, change history and records of substantiated objections, making them available to Customers.

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    Annex D - Special instructions for the optional Ai Policy Generator

    D.1. Purpose and activation

    The policy generator is optional. Access may be included in the Customer’s plan, including Pro, an active trial or a relevant Zitado Ai add-on. Availability or payment does not itself constitute the Customer’s instructions. Before the Customer’s information is sent to OpenAI, the Customer must have accepted the specific instructions in this annex and the relevant provider and transfer basis, and an authorised user must request the bounded generation. This annex does not automatically authorise other Ai functions. Customer-specific restrictions continue to take precedence.

    D.2. How the information is processed

    1. Zitado creates an internal or external policy draft from the Customer’s registered governance information. The user reviews the sections to be sent for language refinement.
    2. The browser replaces known organisation, tool, owner, person and team names, registered clauses and certain contact patterns in the body text with placeholders. The substitution list and document basis are sent to Zitado’s server with the request, but are not included as such in the section input sent to OpenAI. Logos and document files are not sent to the model as part of this flow. Headings and free text are not guaranteed to be free of identifiers.
    3. The input consists of format and rule versions, audience (internal/external) and 1–15 sections with an id, heading and body. The server limits headings to 160 characters, body text to 12,000 characters per section and total serialised input to 48,000 characters; unknown fields are removed. Section text may contain personal data.
    4. The server transfers the validated section input via HTTPS to OpenAI Responses with store: false. Zitado receives a rewritten draft, restores known names on the server using the substitution list, and saves the result as a draft in the Customer’s organisation. The Customer’s user must review the content before approving, publishing or using it. Automatic storage as a draft is not approval of its content.

    Limitation: The name replacement removes registered known names but does not guarantee detection of identifiers appearing only within free-text content or inferable from context. This is pseudonymisation and data minimisation, not proven anonymisation under the GDPR. Encrypted HTTPS alone does not amount to a dedicated private network, a guarantee against third-party processing or a guarantee of EU-only processing.

    D.3. Instructions, data categories and exclusions

    The Customer only instructs limited language refinement of relevant governance information for internal or external policy drafting. Special-category data, unnecessary personal identifiers and confidential person-specific content must not be included. ZELLERT shall limit what is transmitted and work to detect unexpected identifiers in free-text fields.

    D.4. OpenAI's role, training and retention

    OpenAI acts as an external processor/subprocessor insofar as personal data are processed. Lawful engagement requires a suitable GDPR Article 28 agreement, appropriate Chapter V documentation for any restricted transfer and an understanding of OpenAI's own downstream subprocessor chain.

    Zitado uses the API setting store: false. This limits normal retention of the response object but is not the same as Zero Data Retention. OpenAI states that API inputs and outputs are not used for model training by default unless the customer opts in, and that abuse-monitoring logs may generally be held for up to 30 days subject to specified exceptions. ZELLERT undertakes not to opt in Customer content for training. Zero retention or processing exclusively within the EU/EEA has not been agreed.

    D.5. Authorised users and transparency

    Only authorised roles may purchase/enable the module or initiate the processing on the Customer's instructions. The Danish and English interfaces shall clearly explain OpenAI's role, limits of minimisation, the prohibition on sensitive information and the need for human review. The Customer may decline to use the add-on and continue using standard Zitado features under the relevant subscription plan.

    D.6. Safeguards and supplier chain

    ZELLERT restricts access to API keys and substitution lists, separates the validated model input from the remaining document basis on the server, and limits error logging to avoid unnecessary disclosure of input and output. The actual server configuration, access controls and provider chain are documented. Any third-country transfers must have a documented valid transfer basis.

    D.7. Separation from the older generator

    The document generator is a separate feature that can send a broader and more identifiable Customer context to OpenAI. Annex D’s pseudonymisation process does not automatically apply to this feature. It may only be used for Customer data within separately documented instructions and the relevant supplier and transfer safeguards. Customer-specific restrictions must be respected; otherwise the feature must not be used for the affected processing.

    D.8. Disabling the add-on

    When the Customer withdraws the instructions, stops using the function or loses the agreed access, no new API calls may be initiated through the module for the affected processing. Saved drafts and local copies follow the normal retention and deletion instructions. Content already lawfully transferred to OpenAI remains subject to the supplier's agreed retention terms; disabling the add-on does not necessarily delete prior safety logs immediately.

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