LegalUpdated 2026-09-23
Data Processing Addendum
This Data Processing Addendum forms part of the Terms of Service. It applies to Customer Content wherever a data protection law applies to that content, including KVKK and the GDPR. If this Addendum conflicts with the Terms on a matter of Customer Content, this Addendum prevails. Nothing in this Addendum increases the liability cap in the Terms.
The contracting party is DATAXID TEKNOLOJİ VE TİCARET ANONİM ŞİRKETİ, Reşitpaşa Mah. Katar Cad. İTÜ Tasarım ve Prototip Merkezi Binası No: 2/41, İç Kapı No: 5, 34469 Sarıyer, İstanbul, Türkiye. These terms are governed by the laws of the Republic of Türkiye, and the courts of Istanbul have jurisdiction, except where a mandatory consumer protection law of your residence says otherwise.
1. Roles and instructions
You are the Data Controller of Customer Content, and we are the Data Processor. Account Data and Service Data are outside the scope of this Addendum. We process Account Data and Service Data as a controller, on the terms of the Privacy Policy.
The Terms, this Addendum, and your use of the service constitute your documented instructions. That use includes uploading a file, training a model for that file, generating synthetic data, running a notebook, and using the agent. We will not comply with an instruction that would cause us to violate applicable law, and we will inform you if we reasonably believe that an instruction would do so.
Customer Content means uploaded files, notebooks, prompts, synthetic output, and the model trained for that data. You own the uploaded files and the synthetic output. The model forms part of your account, and you may use it and delete it. We will not introduce your rows into another customer’s model or into a shared foundation model. The training method remains our property.
Your use of the agent constitutes an instruction to transmit, for that turn, the Customer Content required to respond, including prompts, column profiles, frequent values, row previews, and notebook contents, to Azure OpenAI in Sweden Central, a Microsoft Azure service. A notebook run that you initiate without the agent is not transmitted to Azure OpenAI and remains on our infrastructure in Poland Central.
2. Controller duties
You will ensure that you have a lawful basis for the upload of Customer Content and for the instructions you give us. You are responsible for determining whether any output may be used. Output may still relate to people whose data appears in the source. We do not warrant that output is free of personal data, de-identified, or incapable of being connected to a person.
You will not upload special category data, data concerning health, or data relating to children. The service is not provided for health information that would require a business associate agreement.
3. Deletion and data-subject requests
On your deletion of a dataset, a model, or a generation, we will delete that Customer Content from the service within a reasonable time. On closure of the account, we will delete Customer Content that remains in the service within a reasonable time. We will delete copies retained in backups in the course of the ordinary backup cycle. This Section 3 does not require erasure within a fixed number of days. We will retain Customer Content where retention is required by law.
If a person contacts us in relation to personal data contained in your Customer Content, we will direct that person to you, and you will respond to the person. We will assist you, to the extent of the Customer Content we hold, unless the law prohibits that assistance.
4. Subprocessors
You authorize us to engage the processors named at Subprocessors. We may appoint an additional processor, or replace an existing processor, by posting an updated list that states the date on which the appointment or replacement takes effect. If you object to that appointment or replacement, you may close the account before the stated date. Continued use of the service after that date constitutes acceptance.
5. International transfers
Where Customer Content is transferred from the European Economic Area, the United Kingdom, or Switzerland to Türkiye, the transfer is made under the European Commission’s Standard Contractual Clauses, Module Two (controller to processor), which are incorporated into this Addendum by reference. For those clauses, you are the data exporter and we are the data importer. The subject matter and duration are the service described in the Terms, for so long as we process Customer Content for you. The nature and purpose of the processing, and the categories of data and data subjects, are those described in this Addendum. The technical and organizational measures are the administrative and technical measures we maintain under the Terms. Where we transfer that Customer Content onward to a processor, we do so under the transfer terms of that processor, and not under Module Three of the clauses between you and us.
6. Personal-data breaches
If we become aware of a breach of security leading to accidental or unlawful destruction, loss, alteration, or unauthorized disclosure of Customer Content that we hold, we will notify you without undue delay. You are responsible for any notification to a supervisory authority, and for making that notification within the period required by law.
7. Assistance and audits
We will assist you with data-protection impact assessments and with prior consultations that the law requires in respect of Customer Content we process. You will bear our costs to the extent a request exceeds a reasonable written inquiry. Our obligation to submit to an audit is satisfied by our written answers to your questions and by our making this Addendum and the subprocessors list available to you. We will permit an on-site audit only where applicable law requires it, and you will bear the cost of that audit. Persons we authorize to process Customer Content are under a duty of confidentiality.
8. Duration
This Addendum remains in force for so long as we process Customer Content on your behalf. On its expiry or termination, Section 3 governs deletion and retention.