How we process personal data on your behalf.

1.1 Capitalized terms not defined in this DPA have the meanings given in the Agreement. In this DPA:

1. (a) “Applicable Data Protection Laws” means all laws that apply to the Processing of Customer Personal Data under the Agreement, including, as applicable: Regulation (EU) 2016/679 (the “GDPR”); the GDPR as it forms part of the law of the United Kingdom (the “UK GDPR”) and the Data Protection Act 2018; the Swiss Federal Act on Data Protection of 25 September 2020 (the “FADP”); the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (the “CCPA”); and the comprehensive consumer privacy laws of the other US states, each from the date it takes effect (together with the CCPA, “US State Privacy Laws”).
2. (b) “Authorized Affiliate” means an entity that controls, is controlled by or is under common control with Customer, that is permitted by Customer to use the Service under the Agreement and whose Personal Data is Processed under it.
3. (c) “Controller”, “Processor”, “Data Subject”, “Personal Data”, “Processing” (and “Process”) and “Supervisory Authority” have the meanings given in the GDPR. Where a US State Privacy Law applies, “Controller” includes a “business”, “Processor” includes a “service provider” and “processor”, “Data Subject” includes a “consumer”, and “Personal Data” includes “personal information”, each as defined in that law.
4. (d) “Customer Personal Data” means Personal Data contained in Customer Data that Management OS Processes on Customer’s behalf in providing the Service. It does not include Account Data.
5. (e) “Account Data” means Personal Data that Management OS Processes as an independent Controller to administer its relationship with Customer: names and contact details of account owners, administrators, billing contacts and Users; authentication and billing records; support correspondence; and usage telemetry about the Service. Account Data is governed by the Privacy Policy, not this DPA.
6. (f) “Connected Source” means a third-party system that Customer or a User chooses to connect to the Service (for example a CRM, calendar, email, meeting-recording, messaging or file system) and from which the Service reads data under the credentials and permissions Customer grants.
7. (g) “Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Customer Personal Data transmitted, stored or otherwise Processed by Management OS or its Sub-processors. It does not include unsuccessful attempts or activities that do not compromise the security of Customer Personal Data, such as unsuccessful log-in attempts, pings, port scans or denial-of-service attacks.
8. (h) “Sub-processor” means a third party that Management OS engages to Process Customer Personal Data. A Connected Source is not a Sub-processor: Customer selects it, holds the relationship and controls the credentials.
9. (i) “SCCs” means the standard contractual clauses annexed to Commission Implementing Decision (EU) 2021/914 of 4 June 2021. “UK Addendum” means the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses, version B1.0, issued by the Information Commissioner under section 119A(1) of the Data Protection Act 2018 and in force from 21 March 2022.
10. (j) “Restricted Transfer” means a transfer of Customer Personal Data that would be prohibited by Applicable Data Protection Laws without an approved transfer mechanism, including a transfer from the European Economic Area, the United Kingdom or Switzerland to a country that has no adequacy decision covering it.
11. (k) “AI Output” has the meaning given in the Terms of Service: content the Service generates for Customer.

1.2 “Including” means including without limitation. Headings and the summary at the top of this page are for convenience and do not affect interpretation. A reference to a law includes that law as amended or replaced.

2.1 Roles. As between the parties, Customer is the Controller of Customer Personal Data, or a Processor acting for a third-party Controller, and Management OS is Customer’s Processor (or, where Customer is a Processor, Customer’s sub-processor). For the CCPA, Customer is the business and Management OS is its service provider.

2.2 Account Data. Management OS Processes Account Data as an independent Controller, under the Privacy Policy and Applicable Data Protection Laws. Nothing in this DPA restricts that Processing.

2.3 Details. The subject matter, duration, nature and purpose of the Processing, and the types of Personal Data and categories of Data Subjects, are set out in Annex 1.

2.4 Authorized Affiliates. Customer is responsible for its Authorized Affiliates’ compliance with this DPA. Except where Applicable Data Protection Laws require an Authorized Affiliate to act directly, Customer alone will exercise any right and bring any claim under this DPA on their behalf, and will do so in a combined manner for all of them.

2.5 Duration. This DPA applies for as long as Management OS Processes Customer Personal Data, including after the Agreement ends, until that data is deleted or returned under Section 12.

3.1 Customer is responsible for, and warrants that:

1. (a) it has, and will maintain, a lawful basis for the Processing of Customer Personal Data under the Agreement, and has given every notice and obtained every consent that Applicable Data Protection Laws require, including notices to its own personnel about the workplace data it connects to the Service;
2. (b) it has the authority to connect each Connected Source it connects, and its instructions to Management OS comply with Applicable Data Protection Laws;
3. (c) it will not submit to the Service any category of data the Acceptable Use Policy prohibits (Section 4 of that policy), including special categories of Personal Data under Article 9 of the GDPR, unless the parties agree otherwise in writing; and
4. (d) where it uses AI Output in a decision that produces legal or similarly significant effects for an individual, including a hiring, compensation, promotion, discipline or termination decision, a human with authority to change the outcome will review that decision, as the Acceptable Use Policy requires.

3.2 Customer is responsible for the accuracy and quality of Customer Personal Data and for the settings it chooses in the Service, including which Connected Sources and delivery channels it enables and which Users it admits to its workspace.

4.1 Documented instructions. Management OS will Process Customer Personal Data only on Customer’s documented instructions, including with regard to Restricted Transfers. Customer’s complete instructions at the date of this DPA are: (a) to Process it to provide, maintain, support and secure the Service under the Agreement; (b) as initiated by Users through the Service, including by connecting a Connected Source, asking a question, scheduling a brief or choosing a delivery channel; (c) as set out in this DPA; and (d) as otherwise agreed in writing. Additional instructions require the parties’ written agreement.

4.2 Instructions that infringe the law. Management OS will promptly inform Customer if, in its opinion, an instruction infringes Applicable Data Protection Laws, and may suspend the affected Processing until Customer confirms or changes the instruction.

4.3 Processing required by law. If a law to which Management OS is subject requires Processing other than on Customer’s instructions, Management OS will inform Customer of that legal requirement before Processing, unless that law prohibits it on important grounds of public interest.

4.4 De-identified data. Management OS may derive data that is aggregated and de-identified so that it cannot reasonably be used to identify Customer, a User or any other individual, and use it only to operate, secure and improve the Service, and never to train, fine-tune or improve an AI model. Management OS will take reasonable measures to keep that data de-identified, will not attempt to re-identify it, and will contractually require any recipient to do the same. De-identified data is not Customer Personal Data.

4.5 AI models. Management OS does not use Customer Data, prompts, or AI Output to train, fine-tune, or improve any AI model, including its own. Management OS uses third-party AI model providers only as Sub-processors, on terms that prohibit them from using Customer Personal Data to train or improve their models. Those providers may retain inputs and outputs for a limited period for safety and abuse monitoring, as stated for each on the Sub-processor list.

5.1 Management OS will limit access to Customer Personal Data to personnel who need it to provide the Service, will ensure that each of them is bound by a written obligation of confidentiality (or an appropriate statutory obligation), and will revoke that access promptly when it is no longer needed.

5.2 Management OS personnel will access the content of Customer Personal Data only as needed to provide or support the Service, to respond to a request from Customer, to investigate a suspected security issue or violation of the Acceptable Use Policy, or to comply with law.

6.1 Authorization. Customer gives Management OS general written authorization to engage Sub-processors. The Sub-processors engaged at the date of this DPA are those listed at mgmt-os.ai/subprocessors, which forms Annex 4.

6.2 Obligations. Before a Sub-processor Processes Customer Personal Data, Management OS will carry out reasonable due diligence on its data protection practices and bind it by a written contract imposing data protection obligations no less protective than those in this DPA, to the extent applicable to the services it provides. Management OS remains fully liable to Customer for each Sub-processor’s performance of those obligations.

6.3 Notice of changes. Management OS will give at least thirty (30) days’ notice before a new Sub-processor begins Processing Customer Personal Data, by updating the Sub-processor list and notifying Customers who have subscribed to changes. Customer may subscribe by emailing privacy@mgmt-os.ai. Where a change is required urgently to keep the Service secure or available, Management OS may give shorter notice, and Customer’s right under Section 6.4 applies in the same way.

6.4 Objection. Customer may object to a new Sub-processor on reasonable data protection grounds by written notice within fifteen (15) days of Management OS’s notice. The parties will then work in good faith to find a resolution, such as a change in configuration that avoids the Sub-processor for Customer. If they cannot resolve the objection within thirty (30) days, Customer may terminate the affected part of the Service by written notice, and Management OS will refund any prepaid fees for the terminated part covering the period after termination.

7.1 Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the Processing, as well as the risk to the rights and freedoms of individuals, Management OS will implement and maintain appropriate technical and organizational measures to protect Customer Personal Data, including the measures in Annex 2.

7.2 Management OS may update those measures as technology and risks change, provided that no update materially reduces the overall security of Customer Personal Data.

8.1 Data Subject requests. Taking into account the nature of the Processing, Management OS will assist Customer by appropriate technical and organizational measures, insofar as possible, to respond to requests from Data Subjects exercising their rights, including rights of access, rectification, erasure, restriction, portability and objection, and rights relating to automated decision-making. The Service lets Customer disconnect sources and export or delete data; where that is not enough for a specific request, Management OS will provide reasonable further help at no additional charge.

8.2 Requests received by Management OS. If Management OS receives a request from a Data Subject that relates to Customer Personal Data, it will forward the request to Customer without undue delay and will not respond to it, other than to tell the Data Subject to contact Customer, unless Customer instructs it to or the law requires it.

8.3 Other assistance. Taking into account the nature of the Processing and the information available to it, Management OS will provide reasonable assistance to Customer in meeting its obligations on security of Processing, notification of breaches, data protection impact assessments and prior consultation with a Supervisory Authority (Articles 32 to 36 of the GDPR and their equivalents), principally by making available the information in this DPA, on the Trust & Security page and in its responses to Customer’s security questionnaires.

9.1 Management OS will notify Customer without undue delay, and in any event no later than seventy-two (72) hours, after becoming aware of a Personal Data Breach. It will notify Customer’s account owner and any security contact Customer has designated.

9.2 The notice will describe, to the extent then known:

1. (a) the nature of the Personal Data Breach, including, where possible, the categories and approximate number of Data Subjects and of Personal Data records concerned;
2. (b) its likely consequences;
3. (c) the measures taken or proposed to address it, including measures to mitigate its possible adverse effects; and
4. (d) a contact point for further information.

9.3 Where not all of that information is available at once, Management OS will provide it in phases without undue further delay. Management OS will take reasonable steps to contain, investigate and remediate the Personal Data Breach, and will reasonably assist Customer with any notification Customer must make to a Supervisory Authority or to Data Subjects.

9.4 Notice under this Section is not an acknowledgment of fault or liability. Management OS will not notify a Supervisory Authority or Data Subject about a Personal Data Breach affecting Customer Personal Data on Customer’s behalf without Customer’s approval, unless the law requires it.

10.1 Management OS will make available to Customer the information reasonably necessary to demonstrate its compliance with this DPA and Article 28 of the GDPR. Customer agrees that this obligation, and any audit right under the SCCs, will first be met by Management OS: (a) answering Customer’s written security questionnaire (such as SIG Lite, the CAIQ or Customer’s own) once in any twelve-month period; (b) answering Customer’s reasonable written follow-up questions about the measures in Annex 2, subject to confidentiality; and (c) providing any third-party audit report or certification it then holds. Management OS does not hold a SOC 2 report today; its status is stated on the Trust & Security page and in Annex 2.

10.2 If that information is not sufficient to demonstrate compliance, or a Supervisory Authority requires it, Customer may conduct an audit, including an inspection, itself or through an independent auditor bound by confidentiality who is not a competitor of Management OS. Customer will give at least thirty (30) days’ written notice, agree the scope and timing in advance, audit no more than once in any twelve-month period (except after a Personal Data Breach or at a Supervisory Authority’s request), conduct it during business hours without unreasonable disruption, and bear its own costs. Management OS will not be required to give access to other customers’ data or to information whose disclosure would compromise the security of the Service.

11.1 Location. Management OS Processes Customer Personal Data in the United States. It and its Sub-processors may Process it in other locations only as stated on the Sub-processor list and in accordance with this Section.

11.2 EEA transfers. For each Restricted Transfer from the European Economic Area, the parties enter into the SCCs, which are incorporated by reference: Module Two (controller to processor) where Customer is a Controller, and Module Three (processor to processor) where Customer is a Processor. The SCCs are completed as set out in Annex 3, Part A.

11.3 UK transfers. For each Restricted Transfer from the United Kingdom, the SCCs apply as varied by the UK Addendum, which is incorporated by reference and completed as set out in Annex 3, Part B.

11.4 Swiss transfers. For each Restricted Transfer from Switzerland, the SCCs apply with the changes in Annex 3, Part C.

11.5 Supplementary measures. Management OS will apply the measures in Annex 2, including encryption in transit and at rest, to Customer Personal Data subject to a Restricted Transfer, and will provide Customer with information it reasonably needs to complete a transfer impact assessment.

11.6 Alternative mechanisms. If Management OS adopts another lawful transfer mechanism recognized by Applicable Data Protection Laws, that mechanism will apply instead to the extent it covers the transfer. If a transfer mechanism is invalidated, the parties will cooperate in good faith to put a valid one in place.

11.7 Precedence. If this DPA conflicts with the SCCs or the UK Addendum, the SCCs or the UK Addendum prevail to the extent of the conflict. Nothing in this DPA limits a Data Subject’s rights under the SCCs.

12.1 During the term, Customer may export Customer Personal Data through the Service or by request to privacy@mgmt-os.ai.

12.2 When the Agreement ends, Management OS will, at Customer’s choice, return or delete Customer Personal Data:

1. (a) Active systems. Customer may request an export within thirty (30) days after the Agreement ends. Management OS will delete Customer Personal Data from its active systems within thirty (30) days after the Agreement ends, or after the export is delivered if later, unless Customer asks for earlier deletion.
2. (b) Backups. Encrypted backups expire on a rolling basis no later than ninety (90) days after creation. Until then, Management OS will not restore Customer Personal Data from a backup except to recover the Service, and the data remains protected by this DPA.
3. (c) Retention required by law. Management OS may retain Customer Personal Data where law requires it, only for as long as required, and will keep it confidential and protected under this DPA.

12.3 On written request, Management OS will confirm deletion in writing. The parties agree that the certification of deletion described in Clauses 8.5 and 16(d) of the SCCs will be provided only on Customer’s written request.

13.1 Where the CCPA applies, Customer discloses Customer Personal Data to Management OS for the limited and specified business purposes of providing, maintaining, supporting and securing the Service under the Agreement. Management OS will:

1. (a) not sell or share Customer Personal Data, as “sell” and “share” are defined in the CCPA;
2. (b) not retain, use or disclose Customer Personal Data for any purpose, including any commercial purpose, other than those business purposes, or as otherwise permitted for service providers by the CCPA and its regulations (Cal. Code Regs. tit. 11, § 7050);
3. (c) not retain, use or disclose Customer Personal Data outside the direct business relationship between Customer and Management OS;
4. (d) not combine Customer Personal Data with personal information it receives from or on behalf of another person, or collects from its own interactions with consumers, except as the CCPA permits for service providers;
5. (e) comply with the CCPA and provide the same level of privacy protection the CCPA requires of businesses;
6. (f) notify Customer if it determines that it can no longer meet its obligations under the CCPA;
7. (g) allow Customer, on notice, to take reasonable and appropriate steps to stop and remediate any unauthorized use of Customer Personal Data, and to ensure Management OS uses it consistently with Customer’s CCPA obligations, through the measures in Sections 8 and 10; and
8. (h) cooperate with Customer in responding to verifiable consumer requests, as set out in Section 8.

13.2 Where another US State Privacy Law applies, Management OS will, in addition to its obligations in this DPA: impose a duty of confidentiality on each person who Processes Customer Personal Data; engage a subcontractor only under a written contract requiring it to meet the processor obligations that law imposes; make available the information Customer reasonably needs to conduct and document data protection assessments; and delete or return Customer Personal Data at the end of the services as set out in Section 12.

13.3 Management OS certifies that it understands and will comply with the restrictions in this Section 13.

14.1 If a public authority, including a law enforcement agency, requests access to Customer Personal Data, Management OS will: (a) try to redirect the authority to request it from Customer; (b) promptly notify Customer, unless the law prohibits notice, in which case it will use reasonable efforts to obtain a waiver of the prohibition; (c) review the legality of the request and challenge it where, after careful assessment, it concludes there are reasonable grounds to consider it unlawful; and (d) disclose only the minimum data the request lawfully requires.

14.2 Management OS publishes the number of such requests it receives in its transparency report.

15.1 Each party’s liability arising out of or in connection with this DPA, whether in contract, tort or any other theory, is subject to the limitations and exclusions of liability in the Agreement, which apply in aggregate to the Agreement and this DPA together.

15.2 Nothing in this DPA limits either party’s liability to a Data Subject under the SCCs or under Applicable Data Protection Laws where such a limitation is not permitted.

This DPA lasts for the term of the Agreement and continues for as long as Management OS or its Sub-processors Process Customer Personal Data. Sections 9, 12, 14, 15 and 18, and any provision that by its nature should survive, survive the end of the Agreement.

17.1 Changes. Management OS may update this DPA to reflect changes in Applicable Data Protection Laws, in Sub-processors (under Section 6) or in the Service. It will give Customer at least thirty (30) days’ notice of a material change, except where a law or Supervisory Authority requires the change sooner. Management OS will not, by an update under this Section, materially reduce the protection this DPA gives Customer Personal Data.

17.2 Prior versions. This version replaces version 1.0 (July 1, 2026). Where Customer’s Agreement incorporated version 1.0, this version applies from the earlier of Customer’s acceptance of it and thirty (30) days after Management OS notifies Customer of it. The version history at the end of this page records each change.

1. (a) Order of precedence. For matters concerning Customer Personal Data, this DPA prevails over the rest of the Agreement, and the SCCs and UK Addendum prevail over this DPA as set out in Section 11.7. Where the Agreement is a signed Master Subscription Agreement with its own order of precedence clause, that clause governs, subject to Section 11.7.
2. (b) Governing law and jurisdiction. This DPA is governed by the law, and subject to the forum, that govern the Agreement, except that the SCCs are governed by the law and forum stated in Annex 3, and the UK Addendum by the law of England and Wales.
3. (c) Severability. If a provision of this DPA is held invalid or unenforceable, the rest remains in effect, and the provision will be read to give effect to the parties’ intent as far as the law allows, or, if that is not possible, as if it had not been included.
4. (d) Notices. Management OS sends notices under this DPA to Customer’s account owner by email or in the Service. Customer sends notices to privacy@mgmt-os.ai, and security matters to security@mgmt-os.ai.
5. (e) Signed copy. Customer may ask for a countersigned copy of this DPA at legal@mgmt-os.ai. A countersigned copy has the same terms as this page on the date it is signed.

Management OS maintains the following measures as of the date of this version. Each describes the production system as it stands, not a plan. Planned measures are stated as such in item (o).

1. (a) Encryption. Customer Personal Data is encrypted in transit over public networks with TLS 1.2 or higher and at rest with AES-256 under keys managed by the hosting provider. Credentials for Connected Sources (OAuth tokens and API keys) are additionally sealed with application-layer envelope encryption (AES-256-GCM).
2. (b) Tenant isolation. Every query in the application is scoped to the requesting workspace. Independently, the database roles reachable from a client hold no privilege to read or change customer tables, and row-level security is enabled on every table in the application schema, denying access by default.
3. (c) Identity and access. Users authenticate through a dedicated identity provider with multi-factor authentication available to every User. Every route that is not public requires authentication, and authorization is checked again in each request handler. Administrative access to production systems is limited to named personnel who need it, on least privilege, through accounts protected by multi-factor authentication.
4. (d) Secure development. Changes reach production through pull requests. Automated checks run on every change, including unit tests, type checks, secret scanning, static code analysis and dependency monitoring, and a build-time control blocks publication of source maps.
5. (e) Application protections. Server-side requests are protected against server-side request forgery; untrusted content is isolated and delimited before it reaches an AI model, to guard against prompt injection; HTTP security headers include HSTS and anti-framing protections; inbound webhooks are verified by signature; and AI endpoints are rate-limited per workspace.
6. (f) Logging and monitoring. Security-relevant actions, such as credential changes, administrative actions, token issuance and revocation and integration changes, are written to an append-only audit log whose records cannot be updated or deleted. Application errors are monitored, with request bodies, query strings, cookies and customer content scrubbed before transmission. Availability is monitored and published on a public status page.
7. (g) Least-privilege connections. Connected Sources are accessed with the narrowest permissions each provider offers for the feature Customer uses; for customer relationship management systems, read-only. Customer can disconnect any source at any time.
8. (h) Vulnerability management. Findings from automated scanning are triaged and fixed by severity. Management OS publishes a vulnerability disclosure policy with a safe-harbor commitment and a machine-readable security contact.
9. (i) Incident response. A written incident response runbook governs detection, triage, containment, notification under Section 9 and post-incident review. Security incidents that warrant it are disclosed in the public security changelog on the Trust & Security page.
10. (j) Backups and recovery. The database is backed up by the hosting provider in encrypted form. Backups expire no later than ninety (90) days after creation.
11. (k) AI governance. Customer Data, prompts and AI Output are not used to train, fine-tune or improve any AI model, including Management OS's own. AI model Sub-processors operate on API terms that prohibit training on Customer Personal Data. AI Output is presented as decision support for human review.
12. (l) Personnel. Personnel with access to Customer Personal Data are bound by written confidentiality obligations, and their access is removed promptly when no longer needed.
13. (m) Sub-processor management. Sub-processors are reviewed before engagement, bound by written data protection terms and listed publicly with their purpose and location.
14. (n) Physical security. Management OS operates no data centers. The Service runs on hosting providers that maintain independent SOC 2 Type II reports for the facilities and infrastructure they operate.
15. (o) Assurance status. SOC 2 Type I is targeted for Q4 2026; Management OS holds no SOC 2 report today. An independent penetration test is planned and has not yet been performed. When either is completed, Management OS will make a summary available to Customer on request, under confidentiality.

The current list of Sub-processors, with each one’s purpose, the data it Processes and its location, is maintained at mgmt-os.ai/subprocessors and is incorporated into this DPA. Changes follow Section 6.