Legal
Data Processing Addendum
AgenticAssure Data Processing Addendum. PDPA-primary (Singapore). Annex I scope, Annex II security measures, Annex III sub-processors, Annex IV international transfers (GDPR/CCPA addenda activated by Order Form).
Effective date: April 20, 2026
Data Processing Addendum (DPA)
STARTER TEMPLATE — NOT LEGAL ADVICE Working draft. Have qualified counsel (Singapore + customer jurisdiction) review before signing. [BRACKETS] = business decision, [LEGAL] = lawyer review needed.
Version: 1.2 · Last updated: 2026-04-20
Scope of this v1.2 rewrite: Singapore-jurisdiction primary (PDPA). Operational claims tightened to commitments AgenticAssure can evidence today; enterprise-tier add-ons clearly separated from baseline measures; international-transfer mechanics moved to Annex IV as an optional addendum activated only on request.
This Data Processing Addendum (“DPA”) forms part of the Master Services Agreement (“MSA”) between NIA Pte. Ltd. (“Processor” / “AgenticAssure”), incorporated in Singapore, and the customer identified in the applicable Order Form (“Controller” / “Customer”).
If there is a conflict between the MSA and this DPA, this DPA prevails for personal data matters.
1. Definitions
- “PDPA” means the Singapore Personal Data Protection Act 2012 and its subsidiary regulations and PDPC advisory guidelines, as amended.
- “Personal Data”, “Process / Processing”, and “Data Breach” have the meanings given in the PDPA. Where Customer is subject to a foreign data-protection law (e.g., the EU GDPR, UK GDPR, CCPA/CPRA, LGPD), equivalent terms in that law apply for the purposes of that Customer’s processing, only to the extent the parties agree in Annex IV or in the Order Form.
- “Customer Personal Data” means Personal Data that AgenticAssure Processes on behalf of Customer in connection with the Service.
- “Sub-processor” means any third party engaged by AgenticAssure to Process Customer Personal Data.
- “Special-Category Data” means Personal Data designated as sensitive or special category under any applicable law (including health, biometric, genetic, political, religious, trade-union, sexual-orientation, or financial-account data) and Personal Data of children under 13.
Jurisdictional note. AgenticAssure is incorporated and operates from Singapore. The PDPA is the primary data-protection regime governing this DPA. Cross-border transfer and foreign-law commitments are addressed in Annex IV and are activated only where the Order Form expressly references them.
2. Roles & Scope
2.1 Customer is the data controller (PDPA “organisation”) of Customer Personal Data. AgenticAssure is the data processor (PDPA “data intermediary”) and processes Customer Personal Data only on Customer’s documented instructions, subject to the MSA and this DPA, except as required by Singapore law (in which case AgenticAssure will inform Customer where lawfully able).
2.2 The subject matter, duration, nature, purpose, types of Personal Data, and categories of Data Subjects are set out in Annex I.
2.3 Special-Category Data prohibition. Customer will not submit Special-Category Data to the Service unless the parties have separately agreed additional safeguards in writing. If AgenticAssure becomes aware that Customer has submitted Special-Category Data without such agreement, AgenticAssure may suspend processing of that data and require written instruction from Customer before resuming.
3. AgenticAssure Obligations
3.1 Confidentiality. Personnel authorised by AgenticAssure to access Customer Personal Data are bound by written confidentiality obligations.
3.2 Security measures. AgenticAssure implements the technical and organisational measures described in Annex II. AgenticAssure undertakes that the measures listed in Annex II as “Baseline” are operational on the Effective Date. Measures listed as “Enterprise add-on” are available only where expressly enabled in the Order Form for the relevant subscription.
3.3 Sub-processors. AgenticAssure may engage the Sub-processors listed in Annex III (also published at https://agenticassure.ai/sub-processors). AgenticAssure will:
(a) impose contractual data-protection and confidentiality obligations on each Sub-processor that are no less protective than this DPA in respect of the Sub-processor’s Processing, including the No Model Training restriction in MSA §4.4; (b) remain liable to Customer for the acts and omissions of its Sub-processors in respect of Customer Personal Data; (c) provide Customer with at least 30 days’ prior notice of any new Sub-processor that will Process Customer Personal Data. Customer may object on reasonable data-protection grounds within 15 days of notice; if the parties cannot resolve the objection within 30 days, Customer may terminate the affected Service for convenience and receive a pro-rata refund of pre-paid Fees for the unused remaining term.
3.4 Data-subject requests. AgenticAssure will, taking into account the nature of Processing, provide reasonable assistance by appropriate technical and organisational measures (insofar as possible) to enable Customer to comply with valid data-subject requests received under applicable law.
3.5 DPIAs / equivalent assessments. AgenticAssure will provide reasonable assistance to Customer with data-protection impact assessments (or equivalents under applicable law), taking into account the nature of Processing and the information available to AgenticAssure.
3.6 Data Breach notification. AgenticAssure will notify Customer without undue delay and in any event within 72 hours after becoming aware of a Data Breach affecting Customer Personal Data, providing the information reasonably available to AgenticAssure that Customer requires to comply with its own notification obligations.
3.7 Customer audit. Customer (or an independent third-party auditor mutually agreed and bound by confidentiality) may, on at least 30 days’ prior written notice, at most once per 12-month period, and at Customer’s cost, audit AgenticAssure’s compliance with this DPA. Audits will be conducted during AgenticAssure’s normal business hours and will not unreasonably interfere with AgenticAssure’s operations or require disclosure of any other customer’s data. AgenticAssure may satisfy this obligation by providing the most recent third-party audit report it holds (if any). AgenticAssure makes no representation that it currently holds a SOC 2 or ISO 27001 certification; any such certification will be referenced in the Order Form or on https://agenticassure.ai/security only when actually in effect.
4. International Transfers (optional — see Annex IV)
4.1 AgenticAssure Processes Customer Personal Data primarily in Singapore (default region: AWS ap-southeast-1) and in the locations listed in Annex III for specific Sub-processor functions.
4.2 Where Customer is subject to a foreign data-protection law that requires a recognised transfer mechanism for the export of Personal Data to Singapore (or to other third countries reached through Annex III), the parties may activate Annex IV by reference in the Order Form. Annex IV provides the EU Standard Contractual Clauses (Module 2: Controller → Processor), the UK International Data Transfer Addendum, and a Transfer Impact Assessment scaffold. Annex IV does not apply unless the Order Form expressly says so, so that customers not subject to those regimes are not asked to accept obligations they do not require.
4.3 For transfers from Singapore, AgenticAssure complies with the requirements of the PDPA and any guidance issued by the Personal Data Protection Commission (PDPC).
5. Return or Deletion of Customer Personal Data
5.1 On termination of the Service, AgenticAssure will, at Customer’s choice and in line with the export window in MSA §10.3, return or delete Customer Personal Data within 60 days of Customer’s documented instruction (or, if no instruction is received, within 120 days of termination), unless retention is required by law. Customer may export Customer Personal Data via the Service prior to termination.
6. Liability
6.1 The limitations of liability in the MSA, including the tiered Super-Cap in MSA §9.2, apply to claims under this DPA. Where customer-specific privacy or security obligations require a higher cap, the parties may agree the higher cap in the Order Form.
7. Term
7.1 This DPA is effective on the same date as the MSA and continues for as long as AgenticAssure Processes Customer Personal Data on Customer’s behalf. Provisions that by their nature should survive termination (including audit rights and confidentiality) survive.
Annex I — Description of Processing
| Item | Description |
|---|---|
| Subject matter | Provision of the AgenticAssure platform: regulatory-grade red-team testing of LLMs and AI agents. |
| Duration | For the term of the MSA, plus the retention period under §5. |
| Nature & purpose | Hosting, processing, and analysing test inputs and outputs; producing reports and dashboards; supporting Authorised Users. |
| Types of Personal Data | Authorised User account data (name, business email, role); audit and log data; any Personal Data Customer chooses to include in test prompts or dataset inputs (Customer-controlled and minimised). |
| Categories of Data Subjects | Customer’s employees and contractors who are Authorised Users; individuals whose Personal Data Customer chooses to include in test inputs (subject to §2.3 — no Special-Category Data without separate agreement). |
| Frequency of transfer | Continuous, for the duration of the Service. |
| Retention period | Up to 120 days post-termination per §5, unless legally required to retain longer. |
Annex II — Technical & Organisational Measures
Honesty principle. This Annex separates measures that are operational today (“Baseline”) from features that are available only where Customer has elected them in the Order Form (“Enterprise add-on”). Anything not listed here is not promised. AgenticAssure will refresh this Annex as the program matures and will not retroactively alter measures committed to a signed customer.
Baseline (operational on the Effective Date)
| Control | Description |
|---|---|
| Encryption in transit | TLS 1.2 or higher for all customer-facing endpoints. |
| Encryption at rest | AES-256 (provided by the underlying cloud provider’s managed services — AWS S3, RDS, EBS, etc.). |
| Tenant data segregation | Logical segregation of Customer Personal Data by tenant in shared-tenant deployments. |
| Access control | Role-based access control with least-privilege defaults. AgenticAssure personnel access to production systems containing Customer Personal Data requires multi-factor authentication. |
| Confidentiality | Personnel sign written confidentiality undertakings as a condition of employment / engagement. |
| No training, no cross-customer learning, no reuse of attack artefacts | Customer Personal Data, prompts, model outputs, attack findings, and vulnerabilities discovered while testing Customer’s systems are not used (a) to train, fine-tune, or evaluate any AI model, (b) as inputs / seeds / training material for the Service as offered to any other customer, or (c) as inputs to any standing attack library. Aggregated anonymised cross-customer threat-intelligence outputs are produced only with Customer’s express prior written opt-in (MSA §4.4). |
| Secure development practices | Source-code review prior to merge; automated dependency scanning and secret scanning in CI; production changes go through pull-request review. |
| Backups | Automated, encrypted backups of production data on the underlying cloud provider’s managed-storage services. |
| Sub-processor diligence | New Sub-processors are reviewed against the obligations in §3.3 before engagement. |
| Incident response | Documented internal incident-response runbook covering detection, containment, customer notification within 72 hours (DPA §3.6), and post-incident review. |
Enterprise add-ons (only where expressly elected in the Order Form)
| Control | Description |
|---|---|
| Single Sign-On (SSO) | SAML 2.0 / OIDC integration with Customer’s identity provider. |
| SCIM provisioning | Automated user lifecycle from Customer’s IdP. |
| Region pinning | Processing pinned to a specific AWS region (e.g., eu-west-1) for a Customer’s tenant. |
| Customer-managed key (BYOK) | Customer-managed encryption keys via AWS KMS for Customer-Tenant data at rest. |
| Restricted inference providers | Customer can restrict or disable the third-party inference Sub-processors used to test Customer’s models. |
| Input redaction / tokenisation | Optional input-side redaction or tokenisation tooling so Customer can further restrict the data leaving Customer’s environment before submission to the Service (per MSA §4.6(d)). |
| Service Level Agreement (SLA) | A monthly availability SLA with service credits, agreed in the Order Form. |
| Disaster Recovery RTO / RPO | Recovery Time / Recovery Point objectives agreed in writing in the Order Form. |
| Independent audit reports | Where AgenticAssure has obtained third-party audit reports (e.g., SOC 2 Type II), these are made available under NDA on request. |
| Annual third-party penetration test | Where contracted, the most recent executive summary is shared under NDA. |
| Pre-agreed retention extension | Extended Customer Personal Data retention beyond §5 default, if required by Customer’s regulator. |
What is not promised by default. Specific uptime targets, RTO/RPO numbers, log-retention durations, frequency of penetration testing, and the existence of any specific third-party certification are not committed in this DPA. They become commitments only when written into the Order Form for the relevant subscription.
Annex III — Sub-processors
A live, public version of this list is maintained at https://agenticassure.ai/sub-processors. AgenticAssure will provide at least 30 days’ prior notice before adding a Sub-processor that Processes Customer Personal Data (DPA §3.3(c)).
| Sub-processor | Service | Default processing location | Purpose |
|---|---|---|---|
| Amazon Web Services, Inc. | Cloud infrastructure (compute, storage, networking) | ap-southeast-1 (Singapore) by default; alternative AWS regions available as an Enterprise add-on | Application hosting, storage, backups |
| Netlify, Inc. | CDN / static-site hosting | Global edge network | Marketing-site delivery (agenticassure.ai) |
| Resend, Inc. | Transactional email | EU + US | Account, billing, contact-form, and notification emails |
| Stripe, Inc. (and Stripe Payments Singapore Pte. Ltd.) | Payment processing | US (with Singapore entity for SGD/USD invoicing where applicable) | Subscription billing, invoicing, customer portal |
| OpenAI, L.L.C. | LLM inference (only where Customer’s selected test plan targets an OpenAI-hosted model) | US | Executing test prompts against the Customer-selected target model |
| Anthropic, PBC | LLM inference (only where Customer’s selected test plan targets an Anthropic-hosted model) | US | Executing test prompts against the Customer-selected target model |
| Amazon Bedrock (AWS) | LLM inference (only where Customer’s selected test plan targets a Bedrock-hosted model) | Customer-selected AWS region | Executing test prompts against the Customer-selected target model |
How AgenticAssure handles the no-training commitment with third-party LLM providers
AgenticAssure invokes third-party LLM inference APIs only when a Customer’s selected test plan targets a model hosted by that provider. For each such provider, AgenticAssure configures the integration to use the vendor’s commercial or enterprise API endpoint that, under that vendor’s then-current terms of service for that endpoint, does not use customer-submitted prompts or outputs to train the vendor’s models (as of the date of this DPA: OpenAI Business/Enterprise API, Anthropic API for Business, and AWS Bedrock customer inference all operate on this basis).
If a third-party LLM provider materially changes its terms in a way that conflicts with the no-training commitment in MSA §4.4, AgenticAssure will (a) notify affected Customers, and (b) take reasonable steps to migrate Customer workloads off the affected provider or disable the affected integration, in each case within a reasonable period.
Customers may restrict or disable any third-party inference Sub-processor for their tenant via the “Restricted inference providers” Enterprise add-on (Annex II) or via the Order Form.
Annex IV — International Transfer Addendum (activates only when referenced in the Order Form)
When does Annex IV apply? Only if the Order Form expressly says so. If your organisation is established in Singapore and your Personal Data is processed in Singapore, you do not need Annex IV.
IV.1 EU Standard Contractual Clauses (where Customer is established in the EEA or Switzerland)
The EU Standard Contractual Clauses (Module 2: Controller → Processor, Commission Implementing Decision (EU) 2021/914) apply and are incorporated by reference, completed using the information in Annexes I, II, and III. Optional docking clause: selected. Clause 17 governing law: Ireland. Clause 18 forum: Ireland. Competent supervisory authority: Ireland Data Protection Commission. For Switzerland, references to GDPR are read as references to the Swiss Federal Act on Data Protection.
IV.2 UK International Data Transfer Addendum (where Customer is established in the UK)
The UK International Data Transfer Addendum to the EU Commission Standard Contractual Clauses (version B1.0) issued by the UK ICO is incorporated by reference, modifying the EU SCCs in §IV.1 for UK transfers.
IV.3 Transfer Impact Assessment (TIA)
AgenticAssure has prepared a starter TIA covering Singapore as a destination jurisdiction (legal/TIA_TEMPLATE.md in the AgenticAssure repository). AgenticAssure will reasonably assist Customer with Customer’s own TIA obligations.
IV.4 CCPA/CPRA — Service Provider undertaking (where Customer is a California “business”)
Where applicable, AgenticAssure acts as a “Service Provider” under the CCPA/CPRA in respect of “personal information” of California residents in Customer Personal Data, and undertakes that it will not (a) sell or share that personal information; (b) retain, use, or disclose it outside the direct business relationship with Customer or for any purpose other than the business purposes specified in this DPA and the MSA; or (c) combine it with personal information received from other sources, except as permitted by the CCPA/CPRA.
IV.5 LGPD (Brazil)
Where Customer is subject to the Brazilian LGPD (Lei Geral de Proteção de Dados, Law No. 13.709/2018), the parties will rely on the LGPD-permitted transfer mechanism most appropriate at the time of transfer; AgenticAssure will offer SCC-equivalent contractual protections on request.
IV.6 Other regimes
For other regimes (e.g., Australia Privacy Act 1988, Hong Kong PDPO), the parties may agree localised commitments in the Order Form.
Signed: see signature page of the MSA. This DPA, including the Annexes activated in the Order Form, is incorporated by reference into the MSA.
Questions? Contact us or email contact@agenticassure.ai.