Legal
Data Processing Addendum
Last updated: 2026-11-01
Adapted from a standard SaaS template and not yet reviewed by a lawyer (note dated 2026-11-01). Questions: legal@persistentmomentum.com.
Summary
This Data Processing Addendum ("DPA") supplements the Terms of Service and Privacy Policyand governs how Persistent Workforce ("Processor") processes personal data on behalf of customers ("Controller"). It identifies the categories of personal data processed, the sub-processors we rely on, the security measures we maintain, and the rights you can exercise.
1. Roles
Controller. The customer determines the purposes and means of processing the customer and lead data it keeps in the Service. The customer is the controller of that data.
Processor.Persistent Workforce processes that data only on the customer's documented instructions, which are reflected in the features exposed by the Service and the work the customer approves for its AI employees (pipeline and invoices, post and content generation, publishing to connected accounts, email and text messaging, automations and workflows, analytics).
2. Categories of personal data we process
On the customer's behalf, we process the following data about the customer's own customers and leads: names, email addresses, phone numbers, companies, postal addresses, notes, pipeline stages, invoices, form submissions, and the emails, texts and calls exchanged with them through the Service.
We also process data from accounts the customer connects (for example a Facebook Page, Google Business Profile or Slack workspace): account details, access tokens, and what an AI employee reads or publishes there for the customer.
On the customer's behalf, we also process data about recipients of customer-sent emails (welcome, follow-up, drip, lead notifications): email addresses, names, and delivery metadata (open / click / bounce status returned by our email provider).
3. Sub-processors
The Service relies on the following sub-processors, each bound by their own data processing terms. By using the Service you authorize their engagement.
| Sub-processor | What it does | Data it handles |
|---|---|---|
| Supabase | Database, sign-in and file storage (US region) | All customer data at rest |
| Vercel | Application hosting and CDN | Request data in transit |
| Resend | Email delivery | Recipient address and message content of email sent through the Service |
| Twilio | Text messages and business phone numbers | Phone numbers and the content of texts sent and received |
| OpenAI | AI generation of posts, articles, chat replies and video scripts; text-to-speech | Your business profile, brand voice and the content being drafted |
| Anthropic | AI generation of posts, articles and chat replies | Your business profile, brand voice and the content being drafted |
| Meta | Publishing to Facebook Pages and Instagram, when you connect them | Posts you approve, Page and Instagram account details |
| Publishing to LinkedIn, when you connect it | Posts you approve, profile or Page details | |
| Gmail, Google Calendar and Google Business Profile, when you connect them | Email, calendar events, posts and review replies you approve | |
| TikTok | Sending posts to TikTok, when you connect it | Posts you approve, account details |
| Slack | Reading and posting in your Slack workspace, when you connect it | Channel messages your AI employee reads or sends |
| HubSpot | Reading and updating your HubSpot CRM, when you connect it | Contacts and notes your AI employee reads or writes |
| Calendly | Scheduling, when you connect it | Event types, open times and bookings your AI employee reads |
| Stripe | Billing and subscriptions | Account email and billing details; never your customers' data |
| PostHog | Product analytics | Usage events with anonymized IP |
We notify customers of new sub-processors by updating this page; the "Last updated" date above reflects sub-processor changes.
4. Cross-border transfers
Customer data is stored in the United States (Supabase, US region) and served from Vercel. Platforms the customer connects process the data sent to them under their own terms and in their own regions. EU/UK customers acknowledge that personal data is transferred to the US and processed there. We rely on the standard contractual clauses incorporated into our sub-processors' terms; on request we will furnish copies for the chain relevant to your data.
5. Security measures
We maintain the following technical and organizational measures:
- Encryption in transit (TLS 1.2+) and at rest (AES-256 via Supabase Storage and database).
- Row-Level Security (RLS) on every customer-data table — records are scoped to the owning workspace and cannot be read by other customers.
- HTTPS-only with HSTS preload; CSP, X-Frame-Options, X-Content-Type-Options, Referrer-Policy, and Permissions-Policy headers on every response.
- Webhook signature verification on all inbound integrations (for example Stripe, Twilio and Meta data-deletion requests).
- Tokens for connected accounts encrypted with AES-256-GCM in a table only our server can read.
- Access controls: production access limited to founding operator; service-role credentials rotated on operator change.
- Logging and audit trail: server logs retained ≤ 30 days for security and debugging.
6. Data subject rights
People whose data the customer keeps in the Service can exercise GDPR / CCPA rights (access, correction, deletion, portability) by contacting the customer that uploaded their data. We will support the customer in fulfilling such requests on receipt of a written direction; see legal@persistentmomentum.com for the contact form.
7. Personal data breaches
On confirmed personal data breach affecting customer data, we will notify the customer without undue delay and not later than 72 hours after becoming aware, with the information then available, and update the customer as the investigation progresses.
8. Deletion / return
On termination of the customer's account, customer-owned data (customers, leads, pipeline, posts and content, brand) is retained for 30 days for accidental- deletion recovery, then deleted from active systems. Backups age out within a further 30 days. Customers can request earlier deletion via legal@persistentmomentum.com.
9. Audits
Customers may, upon reasonable written notice, audit our compliance with this DPA no more than once per twelve-month period and at the customer's expense. Audits will be conducted during business hours, will be subject to mutual NDA, and will not unreasonably interfere with operations.
10. Sign a DPA
This published DPA satisfies most customer requirements. Customers whose procurement process requires a signed contract may request one at legal@persistentmomentum.com — include your company name and the email address of the signatory.
11. Contact
Privacy, security, or DPA questions: legal@persistentmomentum.com.
Security disclosures: see /.well-known/security.txt.