At a glance
- DPA annex: this document is incorporated by reference into the Agreement and describes the personal data NeuralShift processes on behalf of the Client.
- 5 functional categories: identification and access data, User Content, service operations and security data, content-associated metadata, and technical support communications.
- Data subjects: Authorized Users across all categories.
- Purposes: provision of the Service, alongside access control, identity lifecycle management, and performance and security monitoring.
- Controller processing excluded: platform analytics, product-improvement processing, and voluntary feedback are processed separately by NeuralShift as Controller, as described in the Privacy Notice.
This document forms part of the Data Processing Addendum, which is incorporated by reference into the Agreement under Clause 2.1(c) of the General Terms and Conditions. It is published at a stable public address, in a form permitting its storage and reproduction.
§ 1Categories of Personal Data, Data Subjects, and Purposes of Processing
| Functional Category | Categories of Personal Data ¹ | Categories of Data Subjects | Origin | Specific Purpose of Processing |
|---|---|---|---|---|
| Identification and Access Data | Full name; professional email address; organization; position or function; password in hashed form; session identifiers; authentication tokens; records of account creation, modification, and deactivation | Authorized Users | Provided by the Authorized User or by the Client upon subscription to a Subscription Plan | Access control; identity lifecycle management; provision of the Service |
| User Content (including Private Data) | Files uploaded by the Authorized User (including text documents, spreadsheets, presentations, PDF files, and audio files); prompts, instructions, and queries entered by the Authorized User; outputs generated by the Software in response to Authorized User inputs | Authorized Users ² | Uploaded, entered, or generated by the Authorized User during normal use of the Software’s features, whether directly or through an Integration | Provision of the Service |
| Service Operations and Security Data ³ | IP address; browser type, version, and language; operating system and version; unique device identifiers; access, authentication, and platform activity logs (including timestamps, actions performed, and resources accessed); performance and latency data; error and diagnostic reports; navigation and interface interaction data; cookies and similar tracking technologies. | Authorized Users | Collected automatically during use of the Software | Provision of the Service; performance and security monitoring |
| Content-Associated Metadata | File type, format, and size; date and time of creation, upload, and modification; number of pages and words; detected language; results of semantic analysis and document classification; extracted entities (including names of parties, dates, amounts, and normative references); vector embeddings generated for semantic search purposes; document versions and unique identifiers (chunk IDs) | Authorized Users | Generated automatically by the Software during the processing of User Content | Provision of the Service |
| Technical Support Communications ⁴ | Authorized User’s name and email address; account or session identifier; content of communications exchanged through designated support channels for the purpose of resolving technical issues and service requests; call logs and support interaction records; history of requests and their outcomes. | Authorized Users | Direct interactions with NeuralShift via email or designated support channels relating to Service performance | Provision of the Service |
¹ Given the nature of the Software, which allows Authorized Users to upload any type of content, these categories are merely indicative.
² Given the nature of the Software and the ability of Authorized Users to upload or submit content of any kind, including, in breach of the AUP, content they are not authorized to process, User Content may contain personal data relating to third parties. The identification of Authorized Users as the category of Data Subjects is therefore merely indicative.
³ NeuralShift’s platform analytics and product-improvement processing, including processing carried out through analytics tools, is excluded from this category and processed separately by NeuralShift in its capacity as Controller (see Privacy Notice).
⁴ Voluntary feedback submitted for product-improvement purposes is excluded from this category and processed separately by NeuralShift in its capacity as Controller (see Privacy Notice).