Senex Intelligence Ltd - Customer Data Processing Agreement
1. Introduction
1.1 This Data Processing Agreement (DPA) forms part of the Agreement between Customer and Senex.
1.2 This DPA applies where Senex processes Customer Personal Data as a processor or sub-processor in connection with the Service.
1.3 If there is a conflict between this DPA and the Agreement on the subject of privacy, data protection, or processing of Customer Personal Data, this DPA prevails. If Standard Contractual Clauses, a United Kingdom International Data Transfer Agreement, or a United Kingdom Addendum applies to a Restricted Transfer, that transfer instrument prevails to the extent required by law.
2. Definitions
In this DPA:
Affiliate means an entity that directly or indirectly controls, is controlled by, or is under common control with a party.
Agreement means the applicable commercial agreement between Customer and Senex for use of the Service.
Approved Sub-processor means a Sub-processor listed in Schedule 3 or later appointed in accordance with section 8.
Cloudflare-only default configuration means the default pilot and Entry-tier configuration in which Cloudflare is the only Approved Sub-processor for Customer Personal Data, and Anthropic, Modal, OpenAI, Google artificial-intelligence services, and any other non-Cloudflare artificial-intelligence or document-conversion provider are not enabled for Customer Personal Data unless separately authorised.
Customer Content means documents, prompts, questions, outputs, account data, audit data, and other content submitted to or generated through the Service for Customer.
Customer-enabled Third-Party Service means a third-party service that Customer chooses to enable using Customer's own account, credentials, contract, or application programming interface key, and for which Customer is responsible for the relevant third-party relationship unless an Order Form says otherwise.
Customer Personal Data means any Personal Data contained in Customer Content that Senex processes on behalf of Customer in connection with the Service.
Data Protection Laws means all privacy and data-protection laws applicable to the processing of Customer Personal Data under the Agreement, including, where applicable, the United Kingdom General Data Protection Regulation, the Data Protection Act 2018, the European Union General Data Protection Regulation, the Swiss Federal Act on Data Protection, and any replacement or successor legislation.
Personal Data Breach has the meaning given in applicable Data Protection Laws and, in practical terms, means a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Customer Personal Data.
Restricted Transfer means a transfer of Customer Personal Data to a country or recipient that requires a transfer safeguard under applicable Data Protection Laws.
Service means Mosaic Theory AI and any related Senex Intelligence software, platform, hosted infrastructure, support, and documentation supplied under the Agreement.
Sub-processor means another processor engaged by Senex to process Customer Personal Data on behalf of Customer.
The terms controller, processor, data subject, processing, personal data, and supervisory authority have the meanings given in applicable Data Protection Laws.
3. Roles of the parties
3.1 Customer as controller. Customer is the controller of Customer Personal Data. Customer determines what Customer Content is uploaded, what questions are asked, which users are authorised, and the purposes for which the Service is used.
3.2 Senex as processor. Senex processes Customer Personal Data as Customer's processor, only to provide the Service and only in accordance with Customer's documented instructions.
3.3 Customer acting as processor. If Customer is itself acting as a processor for a third-party controller, then Senex acts as Customer's sub-processor. In that case, Customer is responsible for ensuring that its instructions to Senex are consistent with the instructions and authorisations Customer has received from the relevant controller.
4. Customer instructions
4.1 Customer instructs Senex to process Customer Personal Data only as necessary to:
- provide, secure, maintain, troubleshoot, and improve the Service for Customer;
- receive, store, convert, index, retrieve, and process Customer Content;
- generate embeddings, search results, answers, citations, source links, histories, and audit records for Customer;
- process Customer Personal Data through Approved Sub-processors for the purposes described in Schedule 3;
- transmit Customer Personal Data to a Customer-enabled Third-Party Service only where Customer has enabled and authorised that service in accordance with section 9;
- provide support requested by Customer;
- comply with the Agreement and applicable law; and
- perform the processing described in Schedule 1.
4.2 Senex must not process Customer Personal Data for any purpose other than the purposes described in this DPA, the Agreement, Customer's configuration choices, or Customer's written instructions.
4.3 Senex must not sell Customer Personal Data, use Customer Personal Data for advertising, or use Customer Content to train artificial-intelligence models.
4.4 Senex must not send Customer Personal Data to OpenAI or Google artificial-intelligence services unless Customer expressly authorises that provider through an Order Form, written instruction, product setting, or amendment to this DPA.
4.5 If Senex believes that an instruction infringes applicable Data Protection Laws, Senex will inform Customer unless prohibited by law.
4.6 If Senex is legally required to process Customer Personal Data other than on Customer's instructions, Senex will inform Customer before doing so unless legally prohibited.
5. Customer responsibilities
5.1 Customer is responsible for the lawfulness of Customer Personal Data and Customer Content submitted to the Service, including ensuring that it has a lawful basis, notices, consents, permissions, and authority required to process that data and to instruct Senex to process it.
5.2 Customer is responsible for deciding whether Customer Content is suitable for upload to the Service. Senex does not review, classify, screen, or approve Customer Content for sensitivity, lawfulness, confidentiality, market-sensitivity, or regulatory suitability unless a specific feature is separately enabled and agreed.
5.3 Customer should not upload special category data, criminal-offence data, or other highly sensitive Personal Data unless Customer has confirmed that the upload is lawful, necessary, proportionate, and covered by appropriate safeguards.
5.4 Customer is responsible for managing its authorised users, access rights, account configuration, and internal use of answers or outputs generated by the Service.
5.5 Customer is responsible for assessing and authorising any Customer-enabled Third-Party Service that Customer chooses to enable, including any applicable international-transfer, confidentiality, regulatory, or procurement requirements.
6. Senex processor obligations
6.1 Senex will process Customer Personal Data only on Customer's documented instructions.
6.2 Senex will ensure that persons authorised to process Customer Personal Data are subject to confidentiality obligations.
6.3 Senex will implement and maintain appropriate technical and organisational measures designed to protect Customer Personal Data, as further described in Schedule 2.
6.4 Senex will provide reasonable assistance to Customer as described in sections 11, 12, 13, and 14.
6.5 Senex will maintain records reasonably necessary to demonstrate compliance with this DPA.
6.6 Senex may update its technical and organisational measures from time to time, provided that the updated measures do not materially reduce the overall protection of Customer Personal Data.
7. Confidentiality and personnel access
7.1 Senex will restrict access to Customer Personal Data to personnel who need access for operational reasons, including support, incident response, security, maintenance, and service administration.
7.2 Under normal operation, Senex personnel do not access Customer Content through the product interface.
7.3 If Customer requests support that requires Senex to access Customer Content, Senex will do so only as reasonably necessary to provide that support, and such access will be logged where practicable.
7.4 Behind-the-scenes infrastructure access is restricted to authorised personnel, logged where practicable, and subject to periodic review.
8. Sub-processors
8.1 Customer authorises Senex to use the Approved Sub-processors listed in Schedule 3 for the purposes described there.
8.2 Senex will not authorise a Sub-processor to process Customer Personal Data unless Senex has entered into a written agreement with that Sub-processor imposing data-protection obligations that are materially no less protective than those imposed on Senex under this DPA.
8.3 Senex remains responsible to Customer for the performance of its Sub-processors' data-protection obligations, subject to the liability limits in this DPA and the Agreement.
8.4 Senex may appoint a new or replacement Sub-processor by giving Customer at least 30 days' advance notice, unless shorter notice is reasonably necessary to maintain the security, availability, or continuity of the Service.
8.5 Customer may object to a new or replacement Sub-processor on reasonable data-protection grounds by notifying Senex within 15 days after receiving notice. The parties will work in good faith to resolve the objection.
8.6 If the parties cannot resolve the objection, Senex may suspend or avoid the affected processing, and Customer may terminate the affected Service to the extent the objected-to Sub-processor is necessary to provide it.
8.7 Senex will not use a non-Cloudflare artificial-intelligence model provider or non-Cloudflare document-conversion provider to process Customer Personal Data unless Customer expressly authorises that provider through an Order Form, written instruction, product setting, or amendment to this DPA.
8.8 For clarity, the optional providers listed in Schedule 4 are not Approved Sub-processors unless and until they are expressly added to Schedule 3 or otherwise authorised in accordance with this DPA.
8.9 Cloudflare is Senex's core infrastructure provider and the sole Approved Sub-processor for the Cloudflare-only default configuration. Senex configures Customer Content storage and other persistent data stores for European Union jurisdiction where supported by the relevant Cloudflare service and confirmed in Senex's technical configuration.
8.10 Cloudflare processing is subject to Cloudflare's Data Processing Addendum, applicable transfer safeguards, and service-specific data-localisation capabilities. Cloudflare edge compute, artificial-intelligence inference, vector search, queues, logs, analytics, operational metadata, support, and administrative processing may be subject to Cloudflare's global network, service-specific regional controls, and documented exceptions. Unless an Order Form expressly states otherwise, Senex does not represent that every Cloudflare processing operation, metadata item, log, inference operation, or vector-search operation occurs only in the European Union.
9. Customer-enabled Third-Party Services and BYOK Anthropic
9.1 Customer may choose to enable a Customer-enabled Third-Party Service only where the feature is available, Senex has not disabled it for the relevant tenant or plan, and the enablement is permitted by the Agreement, this DPA, and any applicable Order Form.
9.2 For Anthropic bring-your-own-key (BYOK), Anthropic may be treated as a Customer-enabled Third-Party Service, rather than a Senex-appointed Approved Sub-processor, only where: (i) Customer supplies an application programming interface key tied to Customer's own Anthropic account; (ii) Customer has accepted Anthropic's applicable commercial and data-processing terms; (iii) Customer instructs Senex to transmit Customer Data to Anthropic for the BYOK feature; and (iv) Senex does not use a Senex-held platform key or independently appoint Anthropic for that processing. If any of those conditions is not satisfied, Anthropic should be treated as a Senex conditional Sub-processor and must be listed or authorised as such before use.
9.3 Before enabling BYOK Anthropic, Customer confirms that: (i) Customer has an active Anthropic account and has accepted Anthropic's applicable commercial and data-processing terms; (ii) Customer authorises Senex to transmit the relevant prompts, retrieved context, request metadata, and other Customer Data to Anthropic using Customer's application programming interface key; (iii) Customer has assessed and accepted the international-transfer consequences of that transmission, including any transfer to or access from the United States or other locations used by Anthropic; and (iv) Customer has put in place any transfer mechanism required for Customer's use case, including Standard Contractual Clauses, the United Kingdom International Data Transfer Addendum or International Data Transfer Agreement, Swiss transfer addendum, adequacy mechanism, or other lawful safeguard as applicable.
9.4 Senex's role for BYOK Anthropic is limited to transmitting the Customer-directed request through the Service, protecting the BYOK credential within Senex-controlled systems, applying Mosaic Theory AI's security controls to Senex-held records, and recording non-content usage or audit metadata. Senex is not responsible for Anthropic's processing under Customer's Anthropic account, except to the extent caused by Senex's breach of its own obligations.
9.5 BYOK Anthropic, Senex-platform Anthropic, Modal, OpenAI, Google artificial-intelligence services, and other non-Cloudflare artificial-intelligence or document-conversion providers are not approved for the Cloudflare-only default configuration unless separately authorised as described in this DPA.
10. International transfers
10.1 Senex will not make a Restricted Transfer of Customer Personal Data unless the transfer is:
- disclosed in this DPA or the Agreement;
- required to provide the Service as configured or instructed by Customer;
- required by law; or
- otherwise authorised in writing by Customer.
10.2 Where a Restricted Transfer is required, Senex will use an appropriate transfer safeguard under applicable Data Protection Laws. Depending on the origin of the data and the applicable regime, this may include the United Kingdom International Data Transfer Agreement, the United Kingdom Addendum to the European Union Standard Contractual Clauses, the European Union Standard Contractual Clauses, an adequacy decision or adequacy regulation, a Swiss transfer addendum, or another legally recognised transfer safeguard.
10.3 The Cloudflare-only default configuration uses Cloudflare as the only Approved Sub-processor. Cloudflare's Data Processing Addendum, transfer safeguards, and service-specific data-localisation capabilities apply to Cloudflare processing. The Service does not rely on a blanket European-Union-only processing claim for all Cloudflare operations.
10.4 Any future non-Cloudflare artificial-intelligence or document-conversion processing must be separately disclosed and authorised under section 8 or section 9 and must be supported by appropriate transfer safeguards before processing begins.
11. Assistance with data-subject rights
11.1 Taking into account the nature of the processing and the information available to Senex, Senex will provide reasonable assistance to Customer in responding to requests by data subjects to exercise rights under applicable Data Protection Laws.
11.2 During the pilot and early production period, assistance with deletion, access, correction, and similar requests may be handled manually.
11.3 Customer is responsible for deciding how to respond to a data-subject request. Senex will not respond directly to a data subject unless instructed by Customer or required by law.
11.4 If Senex receives a request directly from a data subject relating to Customer Personal Data, Senex will, where legally permitted, refer the request to Customer.
12. Security assistance, impact assessments, and regulator consultations
12.1 Taking into account the nature of the processing and the information available to Senex, Senex will provide reasonable assistance to Customer with:
- security of processing;
- Personal Data Breach assessment and notification;
- data-protection impact assessments;
- prior consultation with supervisory authorities, where required; and
- reasonable requests for information about Senex's processing of Customer Personal Data.
12.2 Senex may satisfy assistance requests by providing existing security documentation, technical descriptions, audit-trail exports, responses to reasonable questionnaires, or other compliance evidence.
13. Personal Data Breach notification
13.1 Senex will notify Customer without undue delay and, in any event, within 72 hours after becoming aware of a Personal Data Breach affecting Customer Personal Data.
13.2 Senex's initial notification may be preliminary and may be provided before Senex has completed its investigation.
13.3 To the extent reasonably available, Senex's notification will include:
- a description of the nature of the Personal Data Breach;
- the categories and approximate number of affected data subjects and records, where known;
- the likely consequences of the Personal Data Breach, where known;
- the measures taken or proposed to address the Personal Data Breach;
- measures proposed to mitigate possible adverse effects; and
- a contact point for further information.
13.4 Senex will provide further information in phases without undue further delay as it becomes reasonably available.
13.5 A notification under this section is not an admission of fault, liability, or legal responsibility.
14. Audit and inspection
14.1 Senex will make available to Customer information reasonably necessary to demonstrate Senex's compliance with this DPA.
14.2 Customer may audit Senex's compliance with this DPA no more than once in any 12-month period, unless a Personal Data Breach or material suspected non-compliance reasonably justifies an additional audit.
14.3 Before requesting an on-site or live systems audit, Customer must first use reasonable alternatives such as security documentation, written responses, audit-trail exports, compliance evidence, and remote review.
14.4 Any audit must be conducted:
- on reasonable prior written notice of at least 30 days, except in urgent circumstances;
- during normal business hours;
- in a manner that does not unreasonably disrupt Senex's business or the Service;
- subject to confidentiality obligations;
- by personnel or auditors who are suitably qualified and not competitors of Senex; and
- at Customer's cost, unless the audit reveals material non-compliance by Senex.
14.5 Senex is not required to disclose information that would compromise the security of the Service, disclose another customer's data, disclose confidential third-party information, or disclose source code.
15. Return and deletion
15.1 On termination or expiry of the Agreement, or on Customer's valid written deletion request, Senex will delete or return Customer Personal Data in accordance with Customer's reasonable instructions, subject to this section.
15.2 Customer documents and data derived from them, including extracted text, search-index data, and cached answers, will be deleted within 30 days after a valid written deletion request or the end or non-renewal of the Agreement, unless a longer retention period is required by law or expressly agreed.
15.3 Short-lived cached answers are retained for up to 24 hours.
15.4 Audit and security logs are retained for at least 365 days and are held in write-once storage configured to prevent modification or early deletion within the retention period. These records may contain Customer Personal Data and will be deleted after the applicable retention period, subject to legal, security, dispute-resolution, or compliance requirements.
15.5 Senex may retain limited business records, support records, deletion confirmations, billing records, and legal records as necessary for legal, accounting, dispute-resolution, security, and compliance purposes.
15.6 Where Customer's stored data is encrypted with a customer-specific encryption key, Senex may use cryptographic deletion by destroying the relevant customer-specific key, rendering the encrypted data unreadable.
15.7 Data in backups, archives, or immutable logs may not be deleted immediately if deletion is technically impracticable or would undermine security, integrity, legal compliance, or disaster recovery. In that case, Senex will protect the data from active processing and delete it according to the applicable deletion cycle or retention period.
16. Liability
16.1 This section is intended to allocate contractual risk between the parties to the maximum extent permitted by law. It does not exclude or limit liability to the extent that liability cannot legally be excluded or limited.
16.2 The liability cap in the Agreement applies to all claims arising out of or relating to this DPA, and any liability under this DPA counts toward, and does not increase, that cap.
16.3 If the Agreement does not contain a liability cap, Senex's total aggregate liability arising out of or relating to this DPA is limited to the fees actually paid by Customer to Senex under the Agreement in the 12 months preceding the event giving rise to liability.
16.4 If Customer is using the Service under a free pilot, free trial, unpaid proof of concept, or other no-fee arrangement, Senex's total aggregate liability arising out of or relating to this DPA is limited to £100.
16.5 Senex is not liable for indirect, incidental, special, consequential, exemplary, punitive, or loss-of-profit damages, or for loss of revenue, loss of goodwill, loss of anticipated savings, or loss of business opportunity, whether arising in contract, tort, breach of statutory duty, or otherwise.
16.6 This DPA does not create any standalone indemnity by Senex in favour of Customer unless expressly stated in the Agreement.
16.7 Each party remains responsible for regulatory fines or penalties imposed directly on that party, except to the extent recovery from the other party is required by applicable law or expressly agreed in the Agreement.
17. Governing law and jurisdiction
17.1 This DPA is governed by the same law as the Agreement.
17.2 If the Agreement does not specify a governing law, this DPA is governed by the laws of England and Wales.
17.3 The courts specified in the Agreement have jurisdiction over disputes relating to this DPA.
17.4 If the Agreement does not specify courts or jurisdiction, the courts of England and Wales have exclusive jurisdiction over disputes relating to this DPA, subject to any mandatory rights of data subjects or supervisory authorities under applicable Data Protection Laws.
18. Changes to this DPA
18.1 Senex may update this DPA from time to time to reflect changes in law, the Service, security measures, or sub-processing arrangements.
18.2 Senex will not materially reduce the protection of Customer Personal Data under this DPA without Customer's consent or a lawful basis to do so.
18.3 Changes to Approved Sub-processors are governed by section 8.
19. Survival
Sections intended by their nature to survive termination, including confidentiality, deletion and retention, audit evidence, liability, governing law, and any provisions relating to retained records, survive termination or expiry of the Agreement.
Schedule 1 - Processing details
1. Subject matter
Senex provides a cloud-hosted research-intelligence software service that allows Customer's authorised users to upload investment-research documents, convert and index those documents, ask natural-language questions about them, and receive AI-assisted, cited, source-linked answers.
2. Duration
For the term of the Agreement, including any pilot, trial, subscription, renewal, support, offboarding, retention, deletion, and legally required retention periods.
3. Nature and purpose of processing
Senex may perform the following processing operations:
- receiving and storing Customer documents;
- converting Word documents and PDFs into text;
- breaking text into sections and building keyword and semantic search indexes;
- generating query and document embeddings;
- searching Customer Content by keyword and meaning;
- retrieving relevant passages in response to authorised-user questions;
- generating answers with citations and source links;
- storing question-and-answer history;
- creating and retaining audit records;
- authenticating and authorising users;
- securing, monitoring, troubleshooting, and maintaining the Service;
- processing operational metadata such as tenant identifiers, document identifiers, job states, and scheduling state;
- responding to support requests; and
- deleting, exporting, or returning Customer Content as instructed.
The purpose of the processing is solely to provide, secure, maintain, support, and improve the Service for Customer.
4. Categories of data subjects
Customer Personal Data may relate to:
- Customer's authorised users, employees, contractors, advisers, and representatives;
- individuals mentioned in Customer documents or prompts;
- individuals appearing in investment-research material uploaded by Customer; and
- other individuals whose Personal Data Customer chooses to include in Customer Content.
5. Categories of Personal Data
Customer Personal Data may include:
- account, login, identity, work-email, organisation, and access-control data;
- document content uploaded by Customer;
- Personal Data included in prompts, questions, answers, citations, and histories;
- retrieved passages and request metadata;
- activity, audit, access, security, and system-event data tied to authorised users;
- support communications relating to Customer's use of the Service; and
- any other Personal Data Customer includes in free-form uploaded documents or questions.
6. Special categories of data
The Service is not designed to require special category data, criminal-offence data, or other highly sensitive Personal Data. Customer is responsible for ensuring that any such data uploaded to the Service is lawful, necessary, proportionate, and appropriately protected.
7. Frequency of processing
Continuous during the term of the Agreement and as otherwise required for retention, deletion, security, support, and legal compliance.
Schedule 2 - Technical and organisational measures
Senex will maintain technical and organisational measures appropriate to the nature of the Service, including the following.
1. Encryption in transit
Data moving between Customer and the Service is transmitted over encrypted connections using modern transport-layer security.
2. Encryption at rest
Readable Customer Content, extracted text, answers, histories, and audit records are encrypted at rest using strong industry-standard encryption.
3. Customer-specific encryption keys
Where a data class is protected by Senex-controlled application encryption, each customer has a separate encryption key for protected stored data. The customer-specific key is itself encrypted under a master key controlled by Senex.
4. Cross-customer owner check
Encrypted data includes a cryptographic owner check tied to the relevant customer. If the Service attempts to read one customer's data with another customer's key, the check fails and no data is returned.
5. Tenant isolation
Customer data is separated by customer, including separate logical databases, separate search indexes, separate document storage, and separate application instances or bindings per customer.
6. Data-localisation configuration and service-specific limits
For the Cloudflare-only default configuration, Senex configures Customer Content storage, audit archives, D1 control-plane data, and worker-log storage for European Union jurisdiction where supported by the relevant Cloudflare service and confirmed in Senex's technical configuration.
This does not mean all Cloudflare processing is European-Union-only. Cloudflare edge compute, artificial-intelligence inference, vector search, key-value storage, queues, Durable Object compute other than the European-Union-pinned consolidation scheduler (see section 15), analytics, operational metadata, support, and administrative processing may operate on Cloudflare's global network or under service-specific regional controls and documented exceptions.
7. Access control
Access to the Service requires authenticated login through a single-sign-on access layer. Unauthenticated requests are rejected at the edge.
8. Personnel access restrictions
Senex restricts access to Customer Personal Data to authorised personnel with operational need. Infrastructure access is logged where practicable and subject to review.
9. Support access
Senex personnel do not normally access Customer Content through the product. Any support access to Customer Content should be requested by Customer, limited to the support purpose, and logged where practicable.
10. Immutable audit trail
The Service maintains audit records of security-relevant and customer-relevant activity, including user questions, answer activity, retrieval activity, and key-management events where applicable. Audit records are written to write-once storage configured to prevent modification or early deletion during the retention period, and audit-record contents are encrypted at rest.
For clarity, the audit trail is not a cryptographic hash chain linking each audit record to the next.
11. Customer audit export
Customer can export its own audit trail to support internal reviews, compliance requests, or regulator-facing evidence without requiring Senex engineering involvement.
12. Secure software practices
Senex follows a controlled deployment process and scans software dependencies for known vulnerabilities.
13. Retention controls
Customer documents and derived content are deleted according to Schedule 5. Audit and security logs are retained for at least 365 days in immutable storage.
14. Technical scope note - derived search indexes
The Service may store mathematical representations of text for by-meaning search. These derived search-index records are separated by customer and protected by the infrastructure provider's service-managed encryption. They may not be protected by the same Senex customer-specific key used for readable documents, extracted text, answers, and audit records. In the Cloudflare-only default configuration, semantic search-index infrastructure may operate under Cloudflare's global service model.
15. Operational metadata
Queues and scheduling components may process operational metadata such as tenant identifiers, document identifiers, job states, debounce timers, and scheduling state. The consolidation-scheduler Durable Object that holds this scheduling state is configured for the European Union jurisdiction (a Cloudflare jurisdiction-restricted Durable Object namespace), consistent with the European Union jurisdiction applied to Customer Content, audit-archive, and control-plane storage. Queue messages and scheduler state are not intended to contain raw Customer Content. Certain transient document-processing components may process Customer Content temporarily to provide conversion, parsing, or encryption functions, but are not intended to persist Customer Content.
16. Roadmap items not included in the standard Service
Unless expressly agreed in an Order Form or amendment, the standard Service does not include:
- customer-managed master keys;
- bring-your-own-key artificial-intelligence providers;
- customer-controlled infrastructure deployment; or
- automated customer self-service deletion for all data classes.
Schedule 3 - Approved Sub-processors
The following Sub-processors are approved for the Cloudflare-only default configuration as of the Effective Date.
| Sub-processor | Purpose | Country / region and localisation posture | Customer Personal Data processed | Notes |
|---|---|---|---|---|
| Cloudflare | Core application infrastructure, edge compute, Workers AI inference, databases, object storage, vector search-index infrastructure, key-value storage, queues, Durable Objects, security controls, analytics/logging, and audit-log storage | Cloudflare global network with service-specific regional controls. Senex configures Customer Content storage, audit archives, D1 control-plane data, the consolidation-scheduler Durable Object, and worker-log storage for European Union jurisdiction where supported and confirmed. Other processing, including edge compute, artificial-intelligence inference, vector search, key-value storage, queues, Durable Object compute other than that consolidation scheduler, analytics, support, administrative processing, and operational metadata, may be global or subject to documented service-specific exceptions. | Customer Content, extracted text, derived search data, prompts, questions, retrieved passages, Outputs, user/account data, audit and security logs, operational metadata, and support data where applicable | Sole Approved Sub-processor for the Cloudflare-only default configuration. Cloudflare processing is subject to Cloudflare's Data Processing Addendum, applicable transfer safeguards, and service-specific data-localisation capabilities. |
No non-Cloudflare artificial-intelligence model provider or non-Cloudflare document-conversion provider is approved for the Cloudflare-only default configuration under this Schedule.
Schedule 4 - Optional or future providers not approved by default
The following providers are not Approved Sub-processors for the Cloudflare-only default configuration unless separately authorised under section 8 or section 9, added to Schedule 3, enabled by Customer, or expressly agreed in an Order Form or amendment.
| Provider | Potential purpose | Country / region | Potential Customer Personal Data processed | Status |
|---|---|---|---|---|
| Anthropic BYOK | Optional Customer-enabled Third-Party Service for answer generation using Customer's own Anthropic account and application programming interface key | Anthropic's service locations, including the United States and other locations used by Anthropic | Prompts, retrieved context, request metadata, Outputs, and other Customer Data transmitted at Customer's instruction | Not approved or enabled by default. May be treated as a Customer-enabled Third-Party Service only if all conditions in section 9 are satisfied. Requires Customer authorisation and Customer assessment of transfer consequences before use. |
| Anthropic platform key | Optional Senex-appointed artificial-intelligence model provider using a Senex-held Anthropic account or key | Anthropic's service locations, including the United States and other locations used by Anthropic | Prompts, retrieved context, request metadata, Outputs, and other Customer Data needed for model processing | Not approved or enabled by default. If used, Anthropic must be treated as a conditional Senex Sub-processor and separately authorised with appropriate transfer safeguards. |
| Modal Labs | Optional document-conversion or transient processing provider | United States or other Modal service locations | Document content and extracted text while being converted or processed, transiently | Not approved or enabled by default. Requires separate customer authorisation and transfer safeguards before use. |
| cloudscale.ch or another Swiss-sovereign hosting provider | Optional future Enterprise-tier hosting and compute substrate | Switzerland | Stored Customer Content, application data, audit data, and operational data for customers on that tier | Not active for the Cloudflare-only default configuration. Enterprise-specific subprocessor, hosting, transfer, service-level, and security terms require separate review before first Enterprise customer signature. |
Senex will not send Customer Personal Data to OpenAI or Google artificial-intelligence services unless Customer expressly authorises that provider through an Order Form, written instruction, product setting, or amendment to this DPA.
Schedule 5 - Retention and deletion
| Data class | Default retention | Deletion / return position |
|---|---|---|
| Uploaded documents | Life of subscription or pilot | Deleted within 30 days after valid written deletion request or end/non-renewal of Agreement, subject to exceptions |
| Extracted text and document-derived data | Life of subscription or pilot | Deleted within 30 days after valid written deletion request or end/non-renewal of Agreement, subject to exceptions |
| Search-index data | Life of subscription or pilot | Deleted within 30 days after valid written deletion request or end/non-renewal of Agreement, subject to exceptions |
| Short-lived cached answers | Up to 24 hours | Automatically expired or deleted |
| Question-and-answer history | Life of subscription or pilot, unless otherwise configured | Deleted within 30 days after valid written deletion request or end/non-renewal of Agreement, subject to exceptions |
| Audit and security logs | At least 365 days | Retained in immutable storage during retention period; deleted after retention period subject to legal, security, dispute-resolution, and compliance requirements |
| Support records and business records | As reasonably required for legal, accounting, support, dispute-resolution, and compliance purposes | Retained only as needed and protected under appropriate controls |
| Backups and archives | According to applicable backup/deletion cycle | Put beyond active use where practicable and deleted according to applicable cycle |
Signature blocks
This DPA may be incorporated into the Agreement by reference, accepted electronically, or signed below.
Senex
Senex Intelligence Ltd
By: ______________________________
Name: ____________________________
Title: _____________________________
Date: _____________________________
Customer
[Customer legal name]
By: ______________________________
Name: ____________________________
Title: _____________________________
Date: _____________________________