Data Processing Addendum

CCPA / TDPSA / VCDPA-compliant processor terms, sub-processor list, breach notice, residency, deletion windows.

Version 1.9 (October 10, 2026 — § 6.2 and § 11. This version replaces version 1.8, posted earlier the same day, and corrects what 1.8 said about where the decision model processes text. § 6.2 adds two Sub-Processors for the Service's typed-decision features, which read text the Service asks about and return only a choice, a yes/no likelihood, or a score, from November 12, 2026: Vercel Inc., whose AI gateway routes each request, and TypeSafe AI, Inc., which runs the decision model and is engaged through Vercel's gateway under Vercel's agreements with it. § 11 is split: § 11.1 keeps the United States processing and storage commitment for all other Customer Personal Information. New § 11.2 says that TypeSafe AI states that it hosts its service in the United States, but that neither provider commits to processing these requests only in the United States: the gateway may receive and process a request in data centers outside the United States, it does not pin the region in which the decision model runs, and a request a provider flags for abuse or safety review may be handled outside the United States. § 11.2 also says that every such request is made with zero data retention and neither provider trains on it, and that no text from a workspace whose AI Security setting is Sealed, or cannot be determined, is sent to either provider. Takes effect November 12, 2026 for Customers already bound to an earlier version (§ 15, MSA § 15.1). No change to roles or to any Customer obligation.) Version 1.8 (October 10, 2026 — § 6.2 and § 11. § 6.2 adds two Sub-Processors for the Service's typed-decision features, which read text the Service asks about and return only a choice, a yes/no likelihood, or a score: TypeSafe AI, Inc., which runs the decision model in the United States, and Vercel Inc., whose AI gateway routes each request to it. § 11 is split: § 11.1 keeps the United States processing and storage commitment for all other Customer Personal Information, and new § 11.2 says that the gateway may receive and process a typed-decision request in data centers it operates outside the United States before forwarding it, that every such request is made with zero data retention and neither provider trains on it, and that no text from a workspace whose AI Security setting is Sealed, or cannot be determined, is sent to either provider. Takes effect November 12, 2026 for Customers already bound to an earlier version (§ 15, MSA § 15.1). No change to roles or to any Customer obligation.) Version 1.7 (October 6, 2026 — Twilio Inc. added to the § 6.2 Sub-Processor table: it delivers the one-time sign-in, verification, and password-reset codes that Customer's authorized users ask for, by text message or automated voice call, and receives only the destination phone number, the code, the delivery channel, and whether the code was later used. Posted, with the public Sub-Processor List, before any code is sent through it (§ 6.3). No change to roles, data residency (§ 11), or any Customer obligation.) Version 1.6 (September 23, 2026 — § 8.1(e) and § 12.2. § 8.1(e) now says that telemetry copies held in routine backups are deleted within the backup-retention window stated in the Privacy Policy (§ 5), and § 12.2 says that information Customer asks Inscendo to delete during the Subscription Term may persist in routine backups for no longer than that same window. Both point at the ninety-day ceiling Privacy Policy § 5 and § 12.1 already state; no retention period is lengthened, and no change to Sub-Processors, roles, data residency, or any Customer obligation.) Version 1.5 (September 2, 2026 — § 4.3 and the customer-configured-provider paragraph of § 6.2 now cover a third-party AI application that Customer connects to the Service under Customer's own account (MSA § 4.9): Customer Personal Information that application requests is transmitted to it at Customer's direction and is thereafter processed under Customer's own agreement with that application's provider, which Customer selects; it is not an Inscendo Sub-Processor and Inscendo's foundation-model agreement in § 4.3 does not govern it. No change to the Sub-Processor table, to roles, to data residency (§ 11), or to any Customer obligation beyond those an optional connection carries. Version 1.4, August 29, 2026 — Backblaze, Inc. added to the § 6.2 Sub-Processor table as off-site immutable backup storage, United States, posted before any Customer Data is stored with it (§ 6.3); new § 8.1(j) discloses that restoration from a backup after a failure may not recover data written after the most recent recovery point and commits Inscendo to notify affected Customers of the recovery point used; § 12.1 now states that any off-site immutable backup copy is retained for a fixed period not exceeding ninety (90) days and cannot be deleted earlier by anyone, including Inscendo, so the Privacy Policy § 5 backup-retention ceiling is confirmed rather than changed. No recovery-time or recovery-point objective is promised. No change to roles, data residency (§ 11, United States only), or any Customer obligation. Version 1.3, August 6, 2026 — Cloudflare and GoDaddy sub-processor entries describe the domains generically rather than naming one; no change to the sub-processor list, its roles, or data residency)Effective June 26, 2026. The Version 1.9 changes (§ 6.2 and § 11) take effect **November 12, 2026** for Customers already bound to an earlier version — at least thirty (30) days' notice under § 15 and MSA § 15.1. For a Customer accepting this DPA for the first time, Version 1.9 is effective on acceptance; the typed-decision features it describes are not switched on for any Customer before November 12, 2026.legal/data-processing.md