Data processing agreement

Last updated October 30, 2026

Draft: the company details in brackets are filled in before Scaled Support is sold. Everything else on this page describes how the service works today.

Our DPA uses the Common Paper DPA Standard Terms, a widely used free standard, with the cover page below. To sign, download the PDF, add your company’s details and signature, and email it to [contact email]. We countersign and send it back.

Download the DPA (PDF)

Agreement

TermValue
AgreementThe Scaled Support Terms of Service (https://scaledsupport.com/terms) between Provider and Customer.
Standard TermsThis Cover Page incorporates the Common Paper DPA Standard Terms Version 1.1 (https://commonpaper.com/standards/data-processing-agreement/1.1). If they conflict, this Cover Page wins.
Approved SubprocessorsSupabase; Vercel; OpenRouter; Amazon Web Services (Bedrock) and Google Cloud (Vertex AI); Microsoft Azure (OpenAI models). The current list, with locations, is at https://scaledsupport.com/security#subprocessors.
Provider Security Contact[contact email]
Security PolicyThe technical and organizational measures in Annex II and at https://scaledsupport.com/security.
Service Provider RelationshipTo the extent the CCPA applies, Provider is Customer's service provider.
Governing Law and Chosen CourtsThe law and courts of [Country of registration].
Restricted TransfersEEA and UK transfers use the Standard Contractual Clauses (Module 2 controller-to-processor, or Module 3 processor-to-processor) and the UK Addendum. Governing Member State: Ireland.
Changes to the Standard TermsDPA Liability Cap: the liability cap in the Agreement applies to this DPA.

Annex I(A): List of parties

TermValue
Data exporterCustomer, as named on the signature block. Role: controller (or processor for its own clients).
Data importer[Company legal name], [Registered address], [Country of registration]. Contact: [contact email]. Role: processor.

Annex I(B): Description of processing

TermValue
ServiceSupport ticketing and AI-drafted replies for messages in the Slack channels, mailbox and website chat Customer connects.
Categories of data subjectsCustomer's own customers and their staff who write in; Customer's employees who use the service; website visitors who use the chat.
Categories of personal dataNames, email addresses, Slack user IDs, message and email content, file names (never file contents), and any personal data people choose to put in their messages.
Special category dataNone intended. Customer should not connect channels used to share special category data.
Frequency of transferContinuous, while Customer uses the service.
Nature and purpose of processingReceiving, storing and organizing messages as tickets; looking up Customer's help docs; generating draft replies with AI models under zero data retention; sending replies Customer approves or allows.
Duration of processingFor the term of the Agreement. Tickets and messages are deleted 365 days after their last activity (Customer can shorten this), and all Customer data within 30 days after the Agreement ends.

Annex I(C): Competent supervisory authority

TermValue
Supervisory authorityThe supervisory authority of the EU member state where Customer is established, or the Irish Data Protection Commission if Customer is outside the EEA.

Annex II: Technical and organizational measures

TermValue
HostingData stored in the EU (Supabase, Ireland, eu-west-1); application in Dublin (Vercel).
EncryptionTLS in transit; encryption at rest; Slack and Gmail tokens additionally encrypted with AES-256-GCM.
Access controlRow-level security separates every workspace's data; only Customer's members can see its tickets; admin-only audit log of every bot action.
Data minimizationOnly connected channels and mailbox are stored; attachments never stored; messages from other channels discarded on arrival; retention-based deletion.
AI providersRequests routed only to endpoints with zero data retention and no training on Customer data.
Request integritySlack requests verified by signature; webhooks acknowledged and queued, never processed in the request.

Common Paper Data Processing Agreement (Version 1.1) free to use under CC BY 4.0.

Data processing agreement · Scaled Support