ZENTRE – Data Processing Agreement (DPA)

English convenience translation. Only the German version (“AVV/DPA”) is legally binding; the English translation is provided for information purposes only. In case of discrepancies, the German version prevails.

Last updated: 06 Jun 2026

1. Preamble, parties, order of precedence

• This Data Processing Agreement (“DPA”) governs the processing of personal data by EZTO TECHNOLOGIES GmbH, Mainz (“Processor”) on behalf of the Customer (“Controller”) in connection with the “Zentre” service.
• This DPA forms part of the main agreement (Terms/order form). In case of conflict, the provisions of this DPA prevail for data protection matters. Otherwise, the main agreement applies.
• GDPR terms apply accordingly.

2. Roles and delineation (Processor vs. Controller)

• Processor scope: This DPA applies to processing in which EZTO processes Customer data as a processor on behalf of the Controller, in particular: provision and operation of Zentre (workspace/chat, user management, access control); inference/orchestration/routing to AI providers per configuration; support and error analysis where Customer data is processed for this purpose; security/abuse prevention/incident handling.
• Controller scope: Where EZTO processes personal data as its own controller (e.g., marketing/website, contract initiation/conclusion, billing/payment processing, company-related compliance), this DPA does not apply; the privacy notices and any separate agreements apply instead.
• No BYOK: Zentre does not currently support “Bring Your Own Key” (BYOK). The selection/activation of AI providers takes place via Zentre configurations.

3. Definitions

• “Customer data”: all personal data that the Controller or its users input, upload, generate, or otherwise provide in Zentre (including content data and metadata).
• “Content data”: workspace/chat content, prompts, uploads, documents, and outputs (where stored/displayed in Zentre).
• “Metadata”: usage, billing, security, and technical telemetry data (e.g., timestamps, request IDs, configuration parameters, token/volume metrics, error messages), where personal.
• “AI provider”: a third-party provider to which Zentre forwards workloads for inference/generation.
• “Subprocessor”: a sub-processor within the meaning of Art. 28 (2) GDPR.
• “Plan”: the seat-based license named in the order form/main agreement (one plan, per user); in addition, Enterprise and Private Cloud options exist by separate agreement.

4. Subject matter, nature, purpose, duration

• The subject matter is the processing of Customer data to provide, securely operate, maintain, support, and further develop Zentre.
• Duration: the term of the main agreement; thereafter deletion/return in accordance with Section 15.
• Details on nature/purpose/data categories/data subjects: Annex 1.

5. Instructions and instruction management

• Processing takes place exclusively on the documented instruction of the Controller (Art. 28 (3) (a) GDPR).
• Documented instructions include: (i) the main agreement/DPA, (ii) product and account configurations (provider selection, allow/deny, routing, regions, retention, logging), (iii) individual instructions in text form (ticket/email).
• Manifestly unlawful instructions are not carried out; the Controller is informed.
• Additional, non-agreed effort may be remunerated in accordance with the main agreement, to the extent permissible.

6. Obligations of the Controller

• Responsible for legal bases/transparency obligations, the content of the Customer data, the configuration (provider/region/retention/logging), and the assessment of the suitability/permissibility of outputs for its own purposes.
• Data minimization: The Controller ensures that only necessary personal data is processed. Special categories (Art. 9 GDPR) only where legally safeguarded and necessary for the use case.
• Religious (church) institutions (optional): Where the Controller is subject to ecclesiastical data protection law (the Catholic KDG or the Protestant DSG-EKD), its provisions apply additionally or with priority. The Parties shall ensure processing accordingly, in particular as regards reporting channels and the competence of the respective ecclesiastical data protection supervisory authority; references to the GDPR apply mutatis mutandis to the KDG/DSG-EKD.

7. Confidentiality

• EZTO ensures that persons authorized to process are bound to confidentiality (Art. 28 (3) (b) GDPR).
• Need-to-know, role-based access, appropriate logging.
• For professional secrecy holders, Section 20 applies in addition.

8. Security of processing (Art. 32 GDPR)

• Appropriate TOMs pursuant to Annex 2 (including TLS, encryption of data at rest at the infrastructure level, RBAC/least privilege, tenant separation, secure SDLC, monitoring/incident response). EZTO operates an ISO/IEC 27001-aligned ISMS and is currently undergoing certification.
• TOMs may be further developed, provided the overall level of security is not reduced.

9. Hosting and data location (default)

• Standard hosting path: EU hosting with Scaleway (Scaleway SAS, France), region Paris (fr-par), to the extent technically provided for in the respective service/plan. Productive processing of Customer data takes place within the EU/EEA.
• Differing Enterprise options may be agreed via order form.

10. Assistance with data subject rights

• EZTO assists the Controller – to the extent possible and taking into account the nature of the processing – with data subject rights (Art. 28 (3) (e) GDPR), in particular through provided functions (export/deletion) and appropriate cooperation.
• Direct data subject requests to EZTO are – where permissible – forwarded to the Controller; no independent response without instruction.

11. Assistance with compliance (Art. 28 (3) (f) GDPR)

EZTO appropriately assists the Controller with Art. 32–34, 35, 36 GDPR. Additional effort may be remunerated in accordance with the main agreement, to the extent permissible.

12. Subprocessors

• General authorization (Art. 28 (2) GDPR).
• Current list: Annex 3 and /legal/subprocessors.
• Changes are announced at least 30 days before they take effect, unless compelling security reasons require a faster change.
• Objections in text form to legal@ezto.io.
• In the event of legitimate objections: a reasonable alternative or a right of termination for the affected part of the service.
• Flow-down: EZTO binds subprocessors at least equivalently (Art. 28 (4) GDPR).
• EZTO remains responsible for compliance with subprocessor obligations within the framework of the GDPR, to the extent legally mandatory.

13. AI providers / AI routing

• Zentre acts as an infrastructure, orchestration, and governance layer. Depending on the configuration, content data is forwarded to AI providers for inference/generation.
• AI gateway Cortecs: Routing to AI providers takes place by default via the EU-based AI gateway Cortecs (Cortecs GmbH, Vienna), which processes data within the EU (zero data retention, where available) and integrates the AI providers as its own subprocessors; the current subprocessor list of Cortecs is decisive in this respect (Annex 3 / /legal/subprocessors).
• Web search (Linkup): Where the web search function is activated, search queries are transmitted to the search provider Linkup (Linkup Technologies SAS, France); activation constitutes a documented instruction; no permanent storage of the queries by EZTO takes place. For the processing of protected secrets (Section 203 StGB), Section 20 applies: in Section 203 mode, web search is deactivated by default.
• Storage/retention in Zentre (chat/workspace): chat/workspace content data is retained for 90 days by default; differing configurations (e.g., Enterprise/Private Cloud) constitute a documented instruction. After expiry of the retention, the content data is deleted or – where technically provided for – irreversibly removed.
• Clarification: additional permanent content “logging” does not take place by default, except in the following exceptional cases.
• Exceptions (logging/support/security): content data may be temporarily processed/stored to the extent necessary for activated debug/logging options, support cases on documented instruction, or security-relevant events – in each case in accordance with the retention configuration and the principle of necessity.
• No training: EZTO does not use content data to train its own or generic models. Use for training purposes is also excluded vis-à-vis the integrated AI providers – where contractually agreed and technically available (e.g., zero data retention).
• Provider-dependent processing: processing by AI providers is provider-dependent; the selection/activation of an AI provider constitutes a documented instruction.
• Professional secrecy: For the processing of protected secrets within the meaning of Section 203 StGB, the model selection in Section 203 mode is restricted to authorized EU endpoints (Section 20; Tier A “EU-controlled” / Tier B “EU-hosted”).
• No guarantees beyond this regarding providers: With respect to AI providers, EZTO owes no guarantees beyond (i) their contractual integration as a subprocessor, to the extent offered/enabled by the respective provider, and (ii) the passing-on of the terms/declarations promised by the provider. Responsibility for an AI provider’s deviations from its own commitments exists only within the framework of mandatory statutory provisions and otherwise in accordance with the liability provisions of the main agreement.
• Knowledge of provider deviations: If EZTO becomes aware of a material deviation by an AI provider from its commitments, EZTO takes appropriate measures (e.g., informing the Controller, recommending/implementing deactivation or routing blocking), to the extent technically possible and economically reasonable.

14. Third-country transfers

• In the standard setup (Scaleway/Paris, Cortecs/EU, and Linkup/EU where applicable), no third-country transfers regularly take place. Where transfers outside the EU/EEA are necessary (e.g., upon selection of non-EU models), they take place in compliance with Art. 44 et seq. GDPR (e.g., adequacy decision, SCC).
• Upon request, EZTO provides the Controller with appropriate information on transfer mechanisms and – where available – supplementary measures.

15. Deletion and return

• During the contract term, deletion takes place according to the configured retention (cf. Section 13 and Annex 4).
• After contract termination: at the Controller’s choice, (i) return (export in commonly used machine-readable formats, where available) or (ii) deletion.
• Production systems: deletion or provision of the export generally takes place within 30 days of contract termination or upon receipt of a corresponding request, unless a legitimate reason prevents this.
• Backups: data may be contained in backups until the expiry of technical deletion/overwrite cycles; backups are not used productively. Backup cycles are typically up to 90 days.

16. Personal data breaches

• EZTO informs the Controller without undue delay, at the latest within 48 hours of becoming aware, of breaches of the protection of personal data.
• The notification contains – where available – the nature of the incident, the categories of data affected, the approximate number, the likely consequences, the remedial measures taken/planned, and a point of contact; updates follow as soon as new information is available.

17. Authority requests / disclosure

• To the extent legally permissible, EZTO informs the Controller without undue delay of legally binding requests from authorities to disclose Customer data.
• Disclosures are – where possible – limited to the necessary minimum; EZTO cooperates in appropriate protective measures.

18. Evidence and audits

• Upon request, EZTO provides appropriate information for the provision of evidence (Art. 28 (3) (h) GDPR), e.g., TOM overviews/policies/reports where available.
• Audits are permitted after prior notice (at least 60 days) and under appropriate conditions; “remote-first”. On-site audits only where there is a justified need.
• Frequency: a maximum of 1 audit per contract year, unless there is a security incident or legitimate cause.
• No (automated) vulnerability/penetration tests against EZTO systems without prior written consent.
• Audits are subject to strict confidentiality; no disclosure of operating/trade secrets beyond the necessary extent.
• Costs: the Controller bears its audit costs; reasonable effort by EZTO may be charged in accordance with the main agreement, to the extent permissible.

19. Documentation

EZTO maintains – to the extent required – a record of processing activities as a processor (Art. 30 (2) GDPR) and provides the Controller upon request with appropriate information/extracts therefrom, to the extent necessary to fulfil the accountability obligation and provided no legitimate confidentiality interests or third-party trade secrets conflict.

20. Involvement in professional secrecy (Section 203 StGB; professional law requirements)

• Scope: To the extent the Controller is subject to a criminally sanctioned confidentiality obligation under Section 203 StGB (or Section 121 of the Austrian Criminal Code, Article 321 of the Swiss Criminal Code) and uses Zentre to process protected secrets, EZTO acts as an “other contributing person” within the meaning of Section 203 (3) StGB. In addition, the relevant professional-law requirements apply, in particular Section 43e of the German Federal Lawyers’ Act (BRAO) in conjunction with Section 2 of the Professional Code for Lawyers (BORA) and Section 62a of the German Tax Advisory Act (StBerG).
• Confidentiality & instruction: EZTO and the persons authorized to process are bound to confidentiality in text form and instructed about the criminal consequences (Section 203 (4) StGB); the obligation continues after contract termination.
• Flow-down: EZTO binds subprocessors and AI providers that may access protected secrets to equivalent confidentiality in text form, to the extent necessary for the service and offered/enabled by the respective provider.
• Section 203 mode (Tiers A/B): The processing of protected secrets is permitted only in a suitable configuration (EU hosting, EU routing, zero data retention, deactivated web search, exclusively authorized model providers). The Controller selects the tier: A “EU-controlled” (only EU-controlled/EU-self-hosted models) or B “EU-hosted” (additionally EU-hosted endpoints); in both tiers, zero data retention applies and web search is deactivated.
• Web search in Section 203 mode: Web search is deactivated in Section 203 mode in both tiers (EU-controlled and EU-hosted).
• Tenant separation (separate tenant): Protected secrets are processed in a tenant physically separated from normal operation, with its own, isolated knowledge base/index. There is no shared knowledge base and no cross-tenant data transfer/cross-tenant search; a tenant switch is a pure identity/navigation switch (e.g., via SSO) without content transfer. The assignment of data to the Section 203 tenant is the responsibility of the Controller (in case of doubt, the Section 203 tenant); secrecy-free/internal matters may be processed in the normal tenant.
• Supplementary agreement: Upon request, EZTO concludes a separate confidentiality agreement under Section 203 StGB, which may also be concluded electronically; in case of conflict, its provisions prevail for Section 203 matters.

21. Final provisions

• Governing law and place of jurisdiction are governed by the main agreement (German law; place of jurisdiction Mainz, to the extent permissible).
• Should any provision of this DPA be or become invalid, the validity of the remaining provisions remains unaffected; the invalid provision is replaced by a valid one that comes closest to its purpose and meets the requirements of the GDPR.
• Amendments and supplements require at least text form.

Annexes to the DPA

Annex 1 — Description of the processing (Art. 28 (3) GDPR)

Subject matter of the processing: provision and operation of the AI orchestration and governance platform “Zentre” (chat assistant, agents, RAG/knowledge tool) as SaaS.

Nature of the processing: automated collection, recording, storage, display, structuring, transmission (to the AI gateway/AI providers and – where activated – to the search provider), restriction, and deletion.

Purpose: provision of the contractually agreed services, user/access management, support/error analysis, security/abuse prevention/incident handling.

Categories of personal data:

• account/organization data (name, business email, organization, roles/permissions);
• usage, billing, security, and technical metadata (timestamps, request IDs, configuration, token/volume metrics, error messages, IP where necessary);
• content data (prompts, uploads, documents, outputs);
• web search queries (only where web search is activated).

Categories of data subjects: users of the Controller (employees); where applicable, third parties named in content/search data (e.g., clients, patients, customers, business partners of the Controller) – depending on the Controller’s inputs.

Special categories (Art. 9 GDPR): only where the Controller inputs such data; this is the responsibility of and on the instruction of the Controller (cf. Section 6).

Duration: for the term of the main agreement; chat/workspace content data 90 days; thereafter deletion/return pursuant to Section 15 and Annex 4.

Place of processing: EU/EEA – hosting Scaleway (France, Paris fr-par); AI routing via Cortecs (EU); web search via Linkup (EU). Third-country transfers only pursuant to Section 14.

Annex 2 — Technical and organizational measures (Art. 32 GDPR)

EZTO operates an ISO/IEC 27001-aligned information security management system (ISMS) and is currently undergoing ISO/IEC 27001 certification. Pending issuance, evidence (TOM documentation, pen-test reports, security questionnaires) is provided upon request.

1. Confidentiality

• Physical access control: hosting in certified EU data centers (Scaleway); physical security by the infrastructure provider.
• System access control: authentication with multi-factor authentication (MFA) for administrative access; role-based assignment of rights (RBAC) according to the least-privilege principle.
• Data access control: need-to-know, role-based access, access logging; restriction of administrative access.
• Separation control: tenant-separated processing (logical tenant separation).
• Pseudonymization/minimization: to the extent possible for the purpose.

2. Integrity

• Transfer control: transport encryption (TLS 1.3) for data in transit.
• Encryption of data/artifacts at rest with AES-256-GCM.
• Input control: logging of relevant actions.

3. Availability and resilience

• Data backup (backups) with defined deletion/overwrite cycles (up to 90 days);
• monitoring, incident response process; business continuity/emergency plan.

4. Procedures for regular review, assessment, and evaluation

• ISMS pursuant to ISO/IEC 27001 (undergoing certification); regular penetration tests; vulnerability management; secure software development lifecycle (secure SDLC).
• Order/subprocessor control: careful selection, contractual binding at least equivalently (Art. 28 (4) GDPR), flow-down.

5. Key management: provider-managed keys; “Bring Your Own Key” (BYOK) is not currently offered.

Annex 3 — Subprocessors

The current subprocessor list (/legal/subprocessors) is decisive. The following are engaged in particular:

The AI model providers are integrated via the Cortecs gateway as its subprocessors (decisive: Cortecs subprocessor list). Changes are announced at least 30 days in advance (Section 12).

Annex 4 — Retention and deletion

• Chat/workspace content data: 90 days by default (uniform); differing only for Enterprise/Private Cloud by separate agreement. After expiry, deletion or irreversible removal.
• Backups: technical deletion/overwrite cycles typically up to 90 days; no productive use.
• Metadata/security logs: only as long as necessary (security, abuse prevention, incident analysis); potentially longer in the event of legal claims/statutory obligations.
• Web search queries: no permanent storage by EZTO.
• After contract termination: export in a commonly used, machine-readable format for 30 days; thereafter deletion pursuant to Section 15.