Legal

Data Processing Agreement

Last modified: May 16th, 2024

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Section 1

Introduction

Incentivai Inc. (operating as StarlixAI) acts as the Processor, while the customer is the Controller. The agreement governs transfer and processing of personal data per GDPR requirements.

Section 2

Purpose

The Controller entrusts the Processor with personal data handling on terms set out in this Agreement and applicable regulations pertaining to the processing of personal data — in particular Regulation (EU) 2016/679. Details appear in Schedule 1.

Section 3

Representations of the Processor

The Processor confirms it has implemented technical and organisational measures ensuring the processing of the Personal Data in accordance with applicable regulations and possesses the necessary expertise.

Section 4

Processing Personal Data

Subsections cover general rules, authorization requirements, and sub-processor engagement. The Processor must process data per Controller instructions, maintain processing records, assist with data subject rights requests, and ensure staff confidentiality.

Section 5

Personal Data Security

Requirements include technical and organisational measures which are appropriate to the threats and nature, scope, context and purposes of processing. Notification of breaches must occur not later than within 48 (forty eight) hours of detection.

Section 6

Right of Control

Controllers may conduct — directly or via an auditor — audits, including inspections, with 14 days' notice, once annually.

Section 7

Termination

Upon termination, the Processor must delete all Personal Data or return carriers containing it.

Section 8

Notices

Correspondence occurs via email or registered mail in English.

Section 9

Final Provisions

Governed by Polish law; disputes resolved through negotiation then court proceedings.

Schedule 1 — Personal Data

Specifies data types (names, emails, IP addresses), subject categories (business partners, users), processing scope, and purpose (service provision).