Data Processing Addendum

The controller-processor contract.

Version 1.0 · Effective May 15, 2026

This Data Processing Addendum ("DPA") forms part of the Terms of Service between you (the "Customer") and Cruma Inc. ("Cruma") for the processing of Personal Data subject to the GDPR, the UK GDPR, the Swiss FADP, or the California Consumer Privacy Act / CPRA.

This DPA is automatically incorporated into your contract with Cruma when you accept the Terms of Service. No counter-signature is required unless your procurement process specifically demands one — in which case email legal@cruma.ai for an executed counterpart.

1 · Definitions

Capitalized terms not defined here have the meanings given in the Terms or in applicable Data Protection Laws.

2 · Roles & scope

Customer is the Controller and Cruma is the Processor with respect to Customer Personal Data. Cruma will process Customer Personal Data only on documented instructions from Customer (which are given through Customer's use of the Service, its configuration choices, and any further written instructions Customer issues).

3 · Processing details

4 · Cruma's obligations

Cruma will:

5 · Customer obligations

Customer represents and warrants that:

6 · Security measures

Cruma will implement and maintain appropriate technical and organizational measures designed to protect Customer Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Current measures include:

Cruma will review and update these measures over time. Material changes will not weaken the overall level of security. The current security posture is summarized at /legal/security.

7 · Sub-processors

Customer authorizes Cruma to engage Sub-processors to process Customer Personal Data, provided that Cruma: (a) imposes data-protection obligations on each Sub-processor that are no less protective than those in this DPA; (b) remains liable to Customer for each Sub-processor's performance.

Categories of Sub-processors and named AI-provider Sub-processors are listed at /legal/subprocessors. Active customers may request the current full list (including specific named vendors in each category) by emailing privacy@cruma.ai.

Change notification. Cruma will give Customer at least 30 days' notice (via email to the workspace owner or via posting on /legal/subprocessors) before adding or replacing a Sub-processor. If Customer reasonably objects to a new Sub-processor on data-protection grounds, the parties will discuss commercially reasonable alternatives. If no resolution is reached, Customer may terminate the affected portion of the Service without penalty.

8 · Personal Data Breach notification

Cruma will notify Customer without undue delay, and in any event within 72 hours of becoming aware, of a Personal Data Breach affecting Customer Personal Data. The notice will describe the nature of the breach, categories and approximate number of affected Data Subjects and records, likely consequences, and measures taken or proposed.

9 · International transfers (SCCs)

Cruma is operated from the United States. For transfers of Customer Personal Data from the EEA, the UK, or Switzerland to the United States or other jurisdictions that have not been deemed to provide adequate protection, the parties incorporate the SCCs as follows:

For transfers from the United Kingdom, the parties incorporate the UK Addendum to the SCCs, with the SCCs as the Approved EU SCCs and this DPA as the Approved Addendum.

For transfers from Switzerland, references to "GDPR" in the SCCs are deemed to include the Swiss FADP, and references to the "supervisory authority" include the Swiss Federal Data Protection and Information Commissioner.

10 · Assistance with Data-Subject requests

Cruma will, taking into account the nature of the processing, assist Customer by appropriate technical and organizational measures (insofar as possible) to respond to Data-Subject requests under Chapter III of the GDPR. To the extent Customer's workspace tools (Settings → Export, Settings → Delete) are not sufficient for the request, Customer may request additional assistance from privacy@cruma.ai.

11 · Audits

Cruma will make available to Customer all information reasonably necessary to demonstrate compliance with this DPA. On reasonable prior written request and no more than once per twelve-month period (unless required by a supervisory authority), Customer may audit Cruma's compliance, either by reviewing third-party audit reports Cruma makes available (e.g., SOC 2 or ISO 27001, once issued) or, if such reports are not sufficient, by conducting a mutually-agreed audit through an independent third-party auditor under reasonable confidentiality terms, at Customer's expense.

12 · Return & deletion

On termination of the Service, Cruma will, at Customer's choice and within 30 days, either return all Customer Personal Data to Customer (via Settings → Export or by bulk export on request) or delete it from active production systems. Backup copies age out on the standard 30-day backup cycle. Cruma may retain Customer Personal Data to the extent and for as long as required by applicable law, subject to continued application of this DPA.

13 · Liability

Each party's liability under or in connection with this DPA is subject to the limitation of liability set out in the Terms of Service, applied per the order of precedence in §15. Nothing in this DPA limits or excludes liability that cannot be limited or excluded under Data Protection Laws.

14 · CCPA / CPRA terms

For Customer Personal Data subject to the CCPA / CPRA, Cruma is a "Service Provider" (or, where applicable, a "Contractor"). Cruma will not:

Cruma certifies that it understands and will comply with these restrictions.

15 · Order of precedence

If a conflict arises among (a) the SCCs / UK Addendum, (b) this DPA, (c) the Terms of Service, the order of precedence is (a) → (b) → (c) on data-protection matters and (c) → (b) → (a) on all other matters.

16 · Contact

Cruma Inc. (Delaware)
Data protection / privacy: privacy@cruma.ai
Legal: legal@cruma.ai
Security: security@cruma.ai