Legal

Data Processing Addendum

Effective date: October 11, 2026

This Data Processing Addendum ("DPA") forms part of the agreement between [Company Legal Entity] ("Euler", "we", "us") and the customer that accepts it ("Customer", "you") for the use of Euler (the "Agreement"), including our Terms of Service. It applies whenever we process Personal Data on your behalf in providing the service. If this DPA and the Agreement conflict on the processing of Personal Data, this DPA wins.

1. Definitions

"Personal Data", "Processing", "Controller", "Processor", "Data Subject" and "Personal Data Breach" have the meanings given in the GDPR. "Data Protection Laws" means the laws that apply to the Processing under this DPA, including the EU General Data Protection Regulation 2016/679 ("GDPR"), the UK GDPR and Data Protection Act 2018, and the California Consumer Privacy Act as amended ("CCPA"). "Customer Personal Data" means Personal Data in the content you upload to or connect to Euler, and Personal Data about your users. "Subprocessor" means a third party we engage to process Customer Personal Data.

2. Roles and instructions

You are the Controller of Customer Personal Data and we are your Processor (and, under the CCPA, your service provider). We process Customer Personal Data only on your documented instructions, which are the Agreement, this DPA, and your configuration and use of the service. We will tell you if we believe an instruction breaks Data Protection Laws. Annex 1 describes the Processing.

You are responsible for having a lawful basis for the Personal Data you bring into Euler, including any notices to and consents from the people it concerns.

3. Our people

Everyone we authorize to process Customer Personal Data is bound by confidentiality obligations, and access is limited to what they need to provide and support the service.

4. Security

We implement the technical and organizational measures in Annex 2, which are designed to protect Customer Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. We may update them, provided the overall level of protection doesn't decrease.

5. Subprocessors

You authorize us to engage the Subprocessors listed in Annex 3. We impose data protection obligations on each Subprocessor that are no less protective than this DPA, and we remain responsible for their performance.

We will give you at least 30 days' notice before adding or replacing a Subprocessor by updating Annex 3 and notifying the account owner by email. You may object on reasonable data protection grounds within that period. If we can't resolve the objection, you may terminate the affected part of the service and receive a pro-rata refund of prepaid fees for it.

6. Helping you meet your obligations

Taking into account the nature of the Processing, we will help you respond to requests from Data Subjects to exercise their rights, much of which you can do yourself in the product. If we receive a request directly, we will pass it to you rather than respond ourselves, unless the law requires otherwise. We will also give you reasonable help with data protection impact assessments and consultations with supervisory authorities about the service.

7. Personal Data Breaches

We will notify you without undue delay, and in any event within 72 hours, after becoming aware of a Personal Data Breach affecting Customer Personal Data. The notice will describe what we know of the breach, the data and people affected, its likely consequences and the steps we are taking, and we will update you as we learn more. Notifying you is not an admission of fault.

8. Deletion and return

You can delete your workspace, and export your specs and audit log, from within the service, and we will provide a full export on request. When a workspace is deleted, or when the Agreement ends, we delete Customer Personal Data within 30 days, unless the law requires us to keep it. Backups are overwritten on their normal rotation.

9. Audits

On request, we will provide the information reasonably needed to demonstrate compliance with this DPA, including answers to your security questionnaire. If that information isn't enough, you may audit our compliance once a year, on at least 30 days' written notice, during business hours, at your cost, and under appropriate confidentiality terms.

10. International transfers

Euler is hosted in the United States, and some Subprocessors process data in the United States. Where Customer Personal Data originating in the European Economic Area, Switzerland or the United Kingdom is transferred to a country without an adequacy decision, the parties agree to the Standard Contractual Clauses adopted by the European Commission in Decision 2021/914 (Module 2, controller to processor), with the UK International Data Transfer Addendum where UK law applies. Those clauses are incorporated into this DPA by reference, with Annexes 1 to 3 completing their appendices, and they prevail if they conflict with this DPA.

11. CCPA

We will not sell or share Customer Personal Data, retain, use or disclose it outside our direct business relationship with you or for any purpose other than providing the service, or combine it with personal information we receive from others except as the CCPA permits. We will tell you if we can no longer meet these obligations.

12. Liability and term

Each party's liability under this DPA is subject to the limitations in the Agreement. This DPA lasts as long as we process Customer Personal Data on your behalf.

Annex 1: Details of the Processing

Subject matterProviding Euler, a product management platform, under the Agreement
DurationThe term of the Agreement, plus the deletion period in section 8
Nature and purposeHosting, storing, indexing and analyzing customer feedback and product data you provide, to produce themes, answers, drafts, roadmaps and measurements, and supporting your account
Data SubjectsYour users of Euler; your customers, prospects and other people whose words or details appear in the feedback, transcripts, tickets, messages and CRM records you connect
Categories of Personal DataNames, email addresses and job information; the content of feedback, support tickets, messages, meeting notes and transcripts; company and account attributes from connected CRMs; usage and log data about your users
Special categoriesNone intended. Please don't upload special-category data unless we've agreed in writing.

Annex 2: Technical and organizational measures

  • Tenant isolation. Workspace membership is checked and queries are scoped to your organization in the application. Every tenant table also carries a PostgreSQL row-level security policy, which requests to your workspace and background processing both run under, so the database enforces the same boundary.
  • Encryption. Data in transit is encrypted with TLS. Connected-tool credentials (OAuth tokens, API keys, webhook secrets) are encrypted in the application before they reach the database.
  • Access control. Short-lived session tokens with single-use refresh tokens; API and MCP tokens stored only as hashes and limited by scope; optional single sign-on, and directory sync (SCIM) that removes people your identity provider deprovisions.
  • Human control of AI actions. Actions that change other systems pass deterministic guardrails and wait for a person by default. Autonomous actions are off unless you enable them.
  • Personal data screening. Optional redaction of personal data on ingest, and screening for personal identifiers before content is pushed to another tool. Screening runs locally.
  • Auditability. An append-only audit log of administrative and AI actions, exportable by you, and a trace linking every model call to the request that caused it.
  • Deletion. Workspace deletion with a 30-day restore window, then permanent deletion.
  • No training. Customer content is not used to train models, by us or by our model Subprocessors.

Annex 3: Subprocessors

SubprocessorPurposeLocationRetention and training
AnthropicAI models for analysis, drafting and synthesisUnited StatesDeletes API inputs and outputs within 30 days; no training
Voyage AIEmbeddings and reranking for searchUnited StatesZero-day retention; no training
Google CloudHosting, database, storage and secretsUnited StatesFor the term of the Agreement
WorkOSAuthentication, single sign-on and directory syncUnited StatesIdentity data only, for the term of the Agreement
StripeBillingUnited StatesBilling data, as required for payments and tax

Integrations you choose to connect (such as Linear, Jira, Slack, Notion, GitHub, PostHog, Amplitude, HubSpot and Granola) receive or provide data at your direction under your own agreements with them, and are not our Subprocessors.

Questions about this DPA: [privacy email].