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Data Processing Addendum

Last updated 2026-07-10. This is a template for a real product and not legal advice — have counsel review before commercial use.

Roles

For customer content, the customer is the data controller and headstreamer is the data processor, processing only on documented instructions.

Scope & duration

Processing covers hosting, display, AI generation, and the intelligence layer, for the term of the agreement.

Sub-processors

Listed on the trust page; we give notice of changes and flow down equivalent obligations.

Security measures

TLS in transit; AES-256 secrets at rest; access controls (SSO, 2FA, RBAC); audit logging; EU residency; tested backups; incident response.

International transfers

Where data leaves the EU (e.g. AI inference), Standard Contractual Clauses and supplementary measures apply.

Data subject requests & breach

We assist the controller with data-subject requests and notify without undue delay on a personal-data breach.

Deletion

On termination, customer data is exported on request and deleted per the retention policy.

DORA

For financial-entity customers, we support the register of information, testing cooperation, and audit rights required under DORA.

Questions: [email protected]

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