Data Processing Agreement & Third-Party Safeguards
Review framework — October 8, 2026
Scope and roles
ApeBot ordinarily determines the purposes of customer-account, licensing and purchase processing and acts as controller for that processing. A supplier acts as processor only where it processes on ApeBot's documented instructions; a payment provider or other supplier may separately act as an independent controller. If ApeBot processes an organization's personal data solely on that organization's instructions, a separately executed business DPA must identify those roles, data, instructions and services. This published framework does not itself bind a supplier or replace an executed contract.
Required processing terms
Each processor engagement must document its duration, nature and purposes; categories of people and data; authorized instructions including transfers; confidentiality commitments; and appropriate security safeguards. Use is limited to the agreed service. A processor must not repurpose data for its own advertising or unauthorized product training.
Subprocessors and transfers
Engagements require specific or general written subprocessor authorization, notice of changes and a meaningful objection route. Equivalent protective obligations must flow to authorized subprocessors. Contracts must identify processing/backup locations and the lawful international-transfer mechanism where required, including applicable approved clauses and supplementary protections. Data-localization restrictions require separate review; consent alone does not automatically cure them.
Rights, incidents and assurance
Suppliers must help handle access, correction, deletion, portability, restriction, objection and regulator requests as applicable. Agreements must require prompt incident notification with relevant facts, continuing assistance, risk assessments where needed, and evidence/audit rights proportionate to the service. Notification decisions to regulators or affected people follow the applicable law and facts; a universal incident deadline is not assumed.
Return, deletion and accountability
At termination, the agreement must specify return or deletion, legal retention exceptions, backup lifecycle, and evidence of completion. ApeBot must maintain a processing inventory, responsible contacts, supplier review dates and signed agreements. Each engagement's status appears at /subprocessors. Customers can request processing information through /privacy-center.
Outstanding execution
Operator identity, contract parties, vendor locations, lawful transfer annexes, retention schedules, security annexes, audit arrangements and signatures require confirmation. Administrators must record signed-contract evidence before marking a vendor control verified. This is a draft contractual framework for review, not evidence that those agreements are executed.