Data Processing Agreement

Version 1.0 · 8 October 2026

About this agreement

What it covers. This Data Processing Agreement (the "Agreement") governs the personal data in recorded sales calls that a company (the "controller", "you") sends to Oyendo for review. Oyendo is run by Artem Baranov, a natural person based in Spain, who processes the calls on your behalf as your processor.

Scope of this version.
- (a) The free review of one recorded call, sent as a file or a link to artem@oyendo.eu.
- (b) The paid audit of up to 50 recorded calls, sent as files or links.
Ongoing reviews through a connection to your phone system or CRM are outside this version. Before they start, both parties agree an updated Annex II and Annex IV in writing.

Structure.
- Part A contains the standard contractual clauses between controllers and processors adopted by the European Commission in Implementing Decision (EU) 2021/915 of 4 June 2021 (the "Clauses"). Only the options were selected. The wording is otherwise unchanged.
- Part B sets out how Oyendo applies the Clauses. As Clause 2(b) allows, it adds commitments that do not contradict the Clauses. If any term in Part B ever conflicts with the Clauses, the Clauses prevail (Clause 4).
- Annexes I to IV form part of the Clauses.

How the Agreement is concluded. You conclude this Agreement in electronic form, as Article 28(9) GDPR allows, in one of two ways. You can tick "I accept the data processing agreement on behalf of my company" and submit the request form on oyendo.eu. You can also reply "I accept" to an email from Oyendo that links to this version. The person who accepts confirms that they are authorised to bind the company named at acceptance. Oyendo records the company name, the contact person, the date and time of acceptance and the version accepted. Within 24 hours Oyendo emails a confirmation that contains a copy of this version and the processor details in Annex I. For a paid audit, Oyendo will ask for acceptance to be confirmed by email from your company's domain before any recording is sent. Oyendo keeps the acceptance record for as long as this Agreement applies and for the limitation period after it ends. You can save or print this page at any time. The Agreement is available in English.

Changes. Oyendo will not change the Clauses. Oyendo emails the contact person at least 14 days before any proposed change to Part B or the Annexes takes effect, and the change applies to you once you accept it. Updates to the list of sub-processors follow Clause 7.7. Publishing a new version on oyendo.eu does not by itself change the agreement you accepted.

Duration. The Agreement applies from acceptance until Oyendo has deleted all personal data it processes for you, as set out in Annex II.

Law. This Agreement is governed by Spanish law, without prejudice to the GDPR.

Part A — Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/915)

SECTION I

Clause 1 — Purpose and scope

(a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

(b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679.

(d) Annexes I to IV are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679.

Clause 2 — Invariability of the Clauses

(a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3 — Interpretation

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4 — Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5 — Docking clause

Not used (optional clause).

SECTION II — OBLIGATIONS OF THE PARTIES

Clause 6 — Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7 — Obligations of the Parties

7.1. Instructions

(a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b) The processor shall immediately inform the controller if, in the processor's opinion, instructions given by the controller infringe Regulation (EU) 2016/679 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing

(a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person's sex life or sexual orientation, or data relating to criminal convictions and offences ("sensitive data"), the processor shall apply specific restrictions and/or additional safeguards.

7.6. Documentation and compliance

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679. At the controller's request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7. Use of sub-processors

(a) GENERAL WRITTEN AUTHORISATION: The processor has the controller's general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 14 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679.

(c) At the controller's request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) The processor shall remain fully responsible to the controller for the performance of the sub-processor's obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

(e) The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8. International transfers

(a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8 — Assistance to the controller

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects' requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller's instructions

(c) In addition to the processor's obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

(1) the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a 'data protection impact assessment') where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;

(2) the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;

(3) the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;

(4) the obligations in Article 32 of Regulation (EU) 2016/679.

(d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9 — Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

(b) in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller's notification, and must at least include:

(1) the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;

(2) the likely consequences of the personal data breach;

(3) the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c) in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller's obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III — FINAL PROVISIONS

Clause 10 — Non-compliance with the Clauses and termination

(a) Without prejudice to any provisions of Regulation (EU) 2016/679, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

(1) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;

(2) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679;

(3) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679.

(c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

(d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

Part B — How Oyendo applies the Clauses

B1. Your calls serve only you. Oyendo processes your calls, transcripts and reviews only to deliver your review or audit and to answer your questions about it. Oyendo does not use them for other customers, for marketing, as examples, or to develop or test its own product, unless you give a separate written instruction.

B2. No model training. Neither Oyendo nor its sub-processors use your calls, transcripts or reviews to train or fine-tune AI models. Oyendo uses Google's paid services, whose terms exclude such use (Annex IV).

B3. Audio. As soon as the transcript has been produced, and in any case within 7 days of receipt, Oyendo deletes the audio file, the email that carried it and every copy on its computer and at Google. Oyendo then empties the mailbox trash. Copies that Oyendo's providers keep for a short time after deletion are listed with their periods in Annex IV.

B4. Transcripts and reviews. - Free review. Oyendo deletes the transcript, the review and the sent review email 30 days after the review is sent, or earlier if you ask. If you order the paid audit within those 30 days, they become part of the audit and follow its retention. - Paid audit. Oyendo keeps transcripts and results for the period you choose when you order. If you do not choose one, Oyendo deletes them 90 days after the results are delivered. - On request. Oyendo deletes any call, transcript or review within 5 working days of your request and confirms the deletion by email.

B5. What the review does not do. Oyendo does not infer or score the emotions of your employees. It does not use anyone's voice to identify or verify them, and it creates no voiceprints. It makes no decisions about any person. Reviews describe what was said and done on the call and suggest wording for next time. Any decision about your employees is yours.

B6. Your responsibilities as controller. You confirm that: - (a) you have a lawful basis to record the calls you send and to have them reviewed; - (b) the people on each call were told that the call is recorded and why, including review with AI tools; - (c) your employees were informed about call reviews under your internal policy; - (d) you will avoid sending calls whose main subject is sensitive data, and you will tell Oyendo if a call you send contains it.

B7. Audits. On request, Oyendo answers written questions and shows its settings and deletion records over a video call. This does not limit your rights under Clause 7.6(c) and (d).

B8. Notices. Oyendo sends notices under this Agreement, including sub-processor changes (Clause 7.7) and breach notifications (Clause 9), to the contact person recorded at acceptance. You can change the contact person by writing to artem@oyendo.eu. If you object to a new sub-processor and Oyendo cannot serve you without it, either party may end the Agreement for the affected calls, and Oyendo deletes them under Clause 10(d).

Annex I — List of parties

Controller(s)

Name: the company named in the request form or in the acceptance email. Address: as given at acceptance. Contact person's name, position and contact details: the person who accepted this Agreement, as recorded at acceptance. Signature and accession date: electronic acceptance, on the date and time recorded by Oyendo and stated in Oyendo's confirmation email. Role: controller.

Processor(s)

Name: Artem Baranov, natural person, trading as Oyendo. Address and tax identification number: stated in Oyendo's confirmation email, which forms part of this Agreement. Contact person's name, position and contact details: Artem Baranov, owner, artem@oyendo.eu. Data protection officer: none appointed. Data protection questions go to artem@oyendo.eu. Supervisory authority of the processor: Agencia Española de Protección de Datos (AEPD), aepd.es. Signature and accession date: Artem Baranov, by publishing this version at oyendo.eu/dpa and by sending the confirmation email after your acceptance. Role: processor.

Annex II — Description of the processing

Categories of data subjects whose personal data is processed - Your employees and contractors who take part in the calls, such as sales representatives and their managers. - The people your team speaks with on the calls, such as prospects, customers and leads, and their colleagues. - Other people named during a call. - Your staff who send calls to Oyendo or receive the results.

Categories of personal data processed - Audio recordings of calls: the voices of participants and everything said on the call. - Transcripts of the calls, with speaker labels and time stamps. - Names, job titles, companies, phone numbers, email addresses and other details spoken during a call. - Call metadata that comes with the file or link: date, time, duration, direction, participants' names or numbers, file names. - Review and audit results: quotes from the call with time stamps, comments on what was said, suggested wording, linked to the employee on the call. - Your playbook or call script, where it contains personal data. - Names and email addresses of your staff who exchange messages with Oyendo about the review.

Sensitive data processed (if applicable) and applied restrictions or safeguards

None is needed or requested. Voice is not processed to identify anyone, so no biometric data within the meaning of Article 4(14) GDPR is processed. If a call contains sensitive data by chance, for example a customer mentioning their health, the following applies: - the data stays only in the transcript; - it is not extracted, tagged or analysed; - it is not quoted in the review; - on your instruction, Oyendo removes it from the transcript; - it follows the same access restrictions and deletion schedule as the rest of the call.

Nature of the processing - Receiving recordings as email attachments to artem@oyendo.eu, or downloading them from a link you send. - Storing recordings on Oyendo's encrypted computer and in its mailbox until transcription. - Automatic transcription with speaker separation, and automatic analysis of the transcript against a sales framework or your playbook, using Google's Gemini models (Annex IV). - Review of every result by Artem Baranov, and writing the review or audit. - Sending the results by email to the contact person, and an optional walkthrough by video call on a platform you choose. Oyendo does not record the walkthrough. - Deleting all data on the schedule below.

Purpose(s) for which the personal data is processed on behalf of the controller - To find the moments in each call where the deal started to slip, measured against a sales framework or your own playbook, each with the time stamp, what the customer said and a suggested line for next time. - For the paid audit, to show recurring patterns across calls and representatives so you can coach your team. - To answer your questions about the results.

Duration of the processing - Audio: until the transcript is produced, at most 7 days after receipt (Part B, B3). - Free review: until 30 days after the review is sent, unless you ask for earlier deletion or order the paid audit (B4). - Paid audit: for the period you choose. If you choose none, until 90 days after the results are delivered (B4). - In all cases the processing ends when Oyendo has deleted the data and confirmed this to you by email.

For processing by (sub-)processors, also specify subject matter, nature and duration of the processing

See Annex IV.

Annex III — Technical and organisational measures

Measures of pseudonymisation and encryption of personal data - Oyendo's computer uses full-disk encryption (FileVault). - Before upload to Google, files are renamed to random identifiers. Requests to Google contain neither your company name nor your staff's contact details. - Data in transit is protected with TLS: Google APIs and downloads over HTTPS, and email over TLS whenever the other mail server supports it.

Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services - Only Artem Baranov has access to call data. Oyendo has no employees or contractors with access. If that changes, the person signs a confidentiality undertaking before getting access, and Oyendo updates this Annex and informs you. - Call data is kept in one working folder on the encrypted computer. That folder is outside any cloud-synced folder (iCloud, Google Drive or similar) and is excluded from backups. - The computer locks automatically when idle and receives operating system security updates.

Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident - You keep the original recordings. Oyendo makes no backups of call data. If a working copy is lost, Oyendo asks you to send it again.

Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures - Before each audit and at least every three months, Oyendo checks the settings listed here. It records the date of the check in its processing log.

Measures for user identification and authorisation - The computer, the Zoho mailbox and the Google Cloud account have unique passwords and two-factor authentication. - The Google Cloud project used for calls holds call data only. Only Artem Baranov's account has access to it.

Measures for the protection of data during transmission - TLS as described above. - For links, Oyendo asks for a link shared with artem@oyendo.eu only, or one that expires. Links that anyone can open are not needed.

Measures for the protection of data during storage - Full-disk encryption on the computer. Provider storage is protected under each provider's security measures (Annex IV). - The mailbox is not forwarded or synced to any other mail service.

Measures for ensuring physical security of locations at which personal data are processed - The computer stays in Oyendo's work premises or with Artem Baranov. It is locked whenever left unattended.

Measures for ensuring events logging - Oyendo keeps a processing log per customer: date each recording was received (by file identifier), date of transcription, date the audio was deleted, date results were sent, date the remaining data was deleted. - Google Cloud records administrative access to the project in its audit logs.

Measures for ensuring system configuration, including default configuration - Google: Gemini models are called through the European Union (eu) endpoint. Request and response logging, grounding with Google Search or Maps, context caching and stored conversations are switched off. Any file passed through a storage bucket sits in the EU, is deleted right after transcription, and an automatic rule deletes it after 24 hours at the latest. - Zoho: the mailbox is hosted in Zoho's EU data centres.

Measures for internal IT and IT security governance and management - Artem Baranov is responsible for all measures in this Annex and keeps this Agreement, the processing log and the record of processing activities up to date.

Measures for certification/assurance of processes and products - Oyendo holds no certifications. The sub-processors' own certifications are described in their documentation (Annex IV).

Measures for ensuring data minimisation - Oyendo asks only for the calls and the playbook needed for the review. You choose which calls to send. - Reviews quote only the parts of the call needed to show a moment and the suggested wording.

Measures for ensuring data quality - Artem Baranov checks every review against the transcript before it is sent. You can ask for corrections at any time.

Measures for ensuring limited data retention - The retention periods in Annex II and Part B, B3–B4. Each deletion date goes into a calendar on the day the data arrives. - Deletion covers local files, the email that carried the recording, the sent email with the review, the mailbox trash and any files stored at Google.

Measures for ensuring accountability - The acceptance record of this Agreement, the processing log and Oyendo's record of processing activities as a processor (Article 30(2) GDPR).

Measures for allowing data portability and ensuring erasure - Results are delivered as documents you keep. On request, Oyendo also sends transcripts as plain text files. - Erasure follows the procedure above. Oyendo confirms it by email.

Assistance to the controller (Clause 8) - Data subject requests that reach Oyendo are forwarded to you within 2 working days, and Oyendo does not answer them itself. - On your instruction, Oyendo finds a person's data by name or phone number across your transcripts and results. It exports, corrects or deletes that data within 5 working days. - On request, Oyendo provides within 10 working days the information you need for a data protection impact assessment or a prior consultation: this Agreement, a description of the processing, the sub-processors and these measures.

Personal data breach (Clause 9.2), additional elements - Oyendo notifies you without undue delay and no later than 48 hours after becoming aware of a breach, by email to the contact person. - The notification also states the time of discovery, the calls and files concerned, and whether a sub-processor was involved. It names who can be contacted and the next update time. - Oyendo keeps a record of every breach, including breaches that did not need notification.

Annex IV — List of sub-processors

The controller authorises the following sub-processors under Clause 7.7(a):

1. Google Cloud EMEA Limited - Address: 70 Sir John Rogerson's Quay, Dublin 2, Ireland (company number 660412). - Contact: through the Google Cloud console and the privacy contacts in Google's Cloud Data Processing Addendum. - Service: Gemini models on Google Cloud Vertex AI (Gemini Enterprise Agent Platform), called through the European Union (eu) endpoint, under the Google Cloud Platform Terms of Service and the Cloud Data Processing Addendum. - Processing: transcription of recordings with speaker separation; analysis of transcripts against a sales framework or your playbook; drafting of review elements that Artem Baranov then checks. - Data: audio, transcripts, playbook text. - Location: model processing on the eu endpoint stays within EU member states. Google group companies and the third parties listed at cloud.google.com/terms/subprocessors may access data from other countries, for example for technical support that Oyendo requests. Those transfers are covered by Google's Cloud Data Processing Addendum, which relies on the EU-US Data Privacy Framework or the Commission's standard contractual clauses. - Duration: for each request. Files in a storage bucket are deleted after transcription and automatically within 24 hours at the latest. Google may log prompts that its automated safety classifiers flag as suspicious, solely to examine possible violations of its use policies. Such logs are kept for up to 90 days in the selected EU region and are not used to train models. - No training: Google does not use customer data to train or fine-tune AI/ML models without the customer's permission or instruction.

2. Zoho Corporation B.V. - Address: Beneluxlaan 4B, 3527 HT Utrecht, the Netherlands. - Contact: dpo@zohocorp.com. - Service: Zoho Mail for artem@oyendo.eu, hosted in Zoho's EU data centres (Amsterdam primary, Dublin secondary). - Processing: receiving recordings and links by email, sending results, correspondence about the review. - Data: email attachments (audio), links, results, names and email addresses of your staff. - Location: EU data centres. Zoho group companies and the third parties Zoho engages may access data from other countries where Zoho operates. Zoho states that these transfers rely on a group agreement based on the Commission's standard contractual clauses. - Duration: until Oyendo deletes the email. After Oyendo empties the trash, Zoho keeps deleted email on its servers for 30 more days and then purges it.

Not sub-processors for call data. Oyendo's website host (Vercel) and the database behind its contact form (Railway) receive no recordings, transcripts or results. The request form stores your company name, your name and role, country, email address, team size and the acceptance record of this Agreement. Oyendo processes those as controller, as its privacy notice describes.