Data processing agreement

This agreement is between the customer who accepts the terms of service ("Customer", the controller) and Parallel Labs, S.L. ("Logika", the processor). It forms part of the terms and is accepted with them; no signature is needed, and we will countersign a copy on request. It applies whenever Logika processes personal data contained in customer data on Customer's behalf, and it is the contract required by Article 28 of Regulation (EU) 2016/679 (GDPR).

Processor: Parallel Labs, S.L., NIF B05585526, Calle Calabria 171, 5º-3ª, 08015 Barcelona, Spain — support@logika.host

1. Definitions

"Personal data", "processing", "controller", "processor", "data subject" and "personal data breach" have their GDPR meanings. "Customer data" is defined in the terms: the spans and log records Customer's applications send to Logika, and what the service derives from them (analytics summaries and identity tables, anomalies and their evidence, queue items). The account data of Customer's users of Logika is not covered here: Logika is its controller, under the privacy policy.

2. Instructions

2.1 Logika processes personal data in customer data only on Customer's documented instructions, unless EU or Member State law requires otherwise, in which case Logika tells Customer first unless that law forbids it.

2.2 Customer's instructions are: the terms and this agreement; Customer's ledgers (which events are evaluated, which parameters are pii, identity or dimension); the project's settings (environments, subscriptions, wake settings); the tier, which sets the retention window; and the actions Customer's members and tokens take through the console, the API and the CLI.

2.3 Logika will tell Customer if, in its opinion, an instruction infringes data protection law.

2.4 Reading the content of a project's decision records to improve the product is not processing on Customer's behalf. Logika does it only while every owner of the project has opted in from their account, as the privacy policy describes, and stops when any owner withdraws. Counting those records without reading them is part of providing the service. Records may contain end users' personal data, which remains processed only on Customer's behalf. Before Logika reads a project's records under the owners' opt-in, that data is replaced by placeholders; Logika never reads end users' personal data for its own purposes.

3. Customer's responsibilities

3.1 Customer decides what its applications send, and is responsible for having a lawful basis for it and for informing the people concerned.

3.2 The service provides encryption in Customer's own application: parameters marked pii, and, when Customer configures a key, every value its ledger does not describe, are encrypted before they leave Customer's process, with a key Logika never holds (Annex II). Customer is responsible for marking personal data and configuring the key. Values that are not encrypted are processed as sent, under the measures in Annex II.

3.3 Customer must not send special categories of personal data (GDPR Art. 9) or data about criminal convictions unless they are encrypted under its key.

4. Confidentiality

Logika ensures that everyone it authorises to process personal data is bound by confidentiality and accesses customer data only as needed to run the service, answer Customer's requests, or meet legal obligations.

5. Security

5.1 Logika implements the technical and organisational measures in Annex II (GDPR Art. 32), and may improve them over time without reducing the overall level of protection.

5.2 Customer is responsible for what is in its control: its tokens and SDK keys, its PII key, its members and their roles, and its own systems, including the coding agent it runs and the AI provider that agent uses.

6. Personal data breaches

Logika notifies Customer without undue delay, and at the latest within 72 hours, after becoming aware of a personal data breach affecting customer data, by email to the project's owners, with what is known: its nature, the data and approximate number of people concerned, the likely consequences, and the measures taken or proposed. It adds information as it becomes available, and helps Customer meet its own obligations under GDPR Articles 33 and 34.

7. Subprocessors

7.1 Customer gives general authorisation for Logika to use the subprocessors listed in Annex III and on the subprocessors page.

7.2 Logika announces any new or replacement subprocessor by email to project owners and on that page at least 30 days before it starts processing customer data. Customer may object on reasonable data protection grounds within that time. If the parties cannot resolve the objection, Customer may end the affected subscriptions and receive a refund of prepaid fees for the unused period.

7.3 Logika binds each subprocessor by written contract to data protection obligations no less protective than these, and remains responsible to Customer for its performance.

8. Location and transfers

Customer data is stored and processed in the European Union (Annex III). Logika will not transfer it outside the European Economic Area without telling Customer under section 7 and without a transfer mechanism valid under GDPR Chapter V.

9. Assisting Customer

9.1 Data subject requests. Customer can read its data through the API and the CLI (logika query, logika journey), decrypting pii values locally with its key. To erase one person's data, Customer asks Logika at support@logika.host, naming the project and the identifying value. Logika erases it from the project's retained data within 30 days, by rewriting or by expiry of the retention window, removes it from identity tables and anomaly evidence, and confirms when done. Logika forwards to Customer any request it receives directly from a data subject about customer data, and does not answer it itself.

9.2 Impact assessments. Logika provides the information it reasonably has to help Customer with data protection impact assessments and prior consultations (GDPR Arts. 35 and 36).

10. Deletion at the end

10.1 Raw data is deleted as it leaves the retention window: expired days are deleted from our servers in the nightly pass; backup copies age out within 14 days of deletion. When a project is deleted, or its subscription ends and is not renewed, it is on notice for 30 days, during which Customer can still read and export everything; on day 30 all of the project's customer data is deleted from our servers; backup copies age out within 14 days of deletion.

10.2 The database's continuous backup holds deleted rows until it ages out, within about 14 days; it is restored only to recover from a failure. Logika keeps no customer data beyond that, except where EU or Member State law requires it.

11. Audits

11.1 Logika makes available the information needed to show compliance with this agreement, and answers Customer's reasonable written questions about it.

11.2 Where that is not enough, Customer, or an independent auditor bound by confidentiality who is not a competitor of Logika, may audit Logika's compliance once a year, on 30 days' notice, during business hours, without access to other customers' data, and at Customer's cost. Subprocessors are audited through their own certifications and reports.

12. Liability and precedence

The limitations of liability in the terms apply to this agreement, except where GDPR does not allow it. If this agreement and the terms conflict on personal data, this agreement prevails. It lasts for as long as Logika processes customer data for Customer.

Annex I: Details of the processing

Annex II: Technical and organisational measures

• Encryption in Customer's application. The logika-otel enhancer encrypts pii parameters, and with a key every value the ledger does not manage (except a fixed list of standard technical fields: HTTP route, method and status code, database system), with AES-SIV (RFC 5297) before data leaves Customer's process. The key is Customer's; Logika never receives it. A pii value arriving unencrypted is dropped and reported to Customer.
• Encryption in transit: TLS on every public host, with HSTS.
• Encryption at rest: full-disk encryption on every server; the database's continuous backup is encrypted with a key kept off the servers.
• Separation: each project's files are stored apart from every other project's; queries run in a sandbox restricted to one project's files.
• Access control for Customer: per-user tokens scoped to one project and role; viewers get none; ingest keys can only write, per ledger and environment; every token, key and sign-in code is stored only as a hash; sessions and tokens are listable and revocable; every API call is recorded against the user who made it.
• Access control for Logika: server access only for named operators, with individual SSH keys and no password logins; operators never hold Customer's PII key.
• Untrusted content: logged values are rendered as inert, delimited data in evidence, so content written by Customer's users cannot instruct Customer's agent.
• Availability and recovery: acknowledged data is written durably before it is acknowledged; copies of every project's files and the database are kept with a second provider in a second country; restore is rehearsed.
• Deletion: expired days are deleted from our servers in the nightly pass; backup copies age out within 14 days of deletion. Project deletion removes the project's files and database rows from our servers on day 30 of its notice; backup copies age out within 14 days of deletion.
• Monitoring: a watchdog checks every service, disk headroom, certificates and backup lag each minute and alerts the operator.

Annex III: Subprocessors of customer data

Stripe, Porkbun and Google process only account data, for which Logika is the controller; they are listed on the subprocessors page with the rest.

This is a summary in plain words. The full text is the one that binds; where the two differ, the full text applies.

If your telemetry contains personal data, about your own users for example, you are the one in charge of it and we handle it only for you. This agreement is the contract the GDPR asks for between the two of us. It comes with the terms; there is nothing to sign.

We use that data only to run Logika for you, as your ledger, your settings and your team's actions say. The people at Logika who can reach it keep it confidential, and our security measures are listed in the annex. Values you mark personal are encrypted in your application with your key, so we cannot read them at all.

If something goes wrong, we email your project's owners within 72 hours of finding out. If we ever add a company that handles your data, we tell you 30 days ahead, and you can leave with a refund if you object. Your telemetry stays in the EU.

Need to erase one person? Email us the project and the value, and within 30 days it is gone from your project's data, identity tables and anomaly evidence, and we confirm. When a project ends, its data is deleted from our servers on day 30 of its notice, and backup copies age out within 14 days of deletion. We can answer your questions about how we protect data, and you can audit us once a year if that's not enough.

We count the decisions your agent records in your projects. Reading what they say is something we do only if every owner agrees, and any personal data about your end users is replaced by placeholders before we read anything.