Data Processing Agreement
ContextFlo Data Processing Agreement
This DPA has two parts: (1) the key terms on this page and (2) the Common Paper DPA Standard Terms Version 1.1 posted at commonpaper.com/standards/data-processing-agreement/1.1 ("DPA Standard Terms"), which is incorporated by reference. If there is any inconsistency between the parts of the DPA, this page controls. Terms capitalized and highlighted below take the meanings given on this page unless otherwise defined in the DPA Standard Terms or the Agreement.
Key Terms
Agreement
This DPA supplements the following agreement: https://contextflo.com/legal/terms
Approved Subprocessors
View the complete list of approved subprocessors at contextflo.com/legal/subprocessors.
Provider Security Contact
Security Policy
Security Policy available at: https://contextflo.com/legal/security
Service Provider Relationship
To the extent the California Consumer Privacy Act (CCPA) applies, the parties agree that ContextFlo acts as a service provider and receives Personal Data from the Customer solely to provide the Service, consistent with the limited and specified business purpose outlined in the Agreement. ContextFlo will not sell or share Personal Data provided under the Agreement, and will not retain, use, or disclose Personal Data except as necessary to deliver the Service or as permitted by Applicable Data Protection Laws. ContextFlo certifies that it understands and will comply with these restrictions, and will notify Customer if it can no longer meet its obligations under the CCPA.
Restricted Transfers
Governing Member State
- EEA Transfers: Netherlands
- UK Transfers: England and Wales
Annex I(A): List of Parties
Data Exporter
- Name: the Customer signing this DPA
- Activities relevant to transfer: See Annex I(B)
- Role: Controller
Data Importer
- Name: the Provider signing this DPA
- Contact person: Vivek Sah, CEO
- Address: 1550 Bay St, San Francisco, California 94123, USA
- Activities relevant to transfer: See Annex I(B)
- Role: Processor
Annex I(B): Description of Transfer and Processing Activities
Service
Contextflo is a cloud-based platform that automatically generates business context around your data and provides them to any LLM doing data analysis.
Categories of Data Subjects
Metadata about customer integrations, configurations, and derived metrics, as well as encrypted connection credentials and OAuth tokens required to connect to customer-managed data sources. ContextFlo does not process or store customer end-user data.
Categories of Personal Data
- Name
- Contact information such as email, phone number, or address
- OAuth identity information (name, email) of customer users and metadata required for account administration
- No end-user or content data is processed
Special Category Data
Is special category data (as defined in Article 9 of the GDPR) processed? No.
Frequency of Transfer
Continuous.
Nature and Purpose of Processing
- Receiving data, including collection, accessing, retrieval, recording, and data entry
- Holding data, including storage, organization, and structuring
- Protecting data, including restricting, encrypting, and security testing
- Erasing data, including destruction and deletion
Duration of Processing
Provider will process Customer Personal Data as long as required (i) to conduct the Processing activities instructed in Section 2.2(a)-(d) of the Standard Terms; or (ii) by Applicable Laws.
Annex I(C): Competent Supervisory Authority
The supervisory authority will be the supervisory authority of the data exporter, as determined in accordance with Clause 13 of the EEA SCCs or the relevant provision of the UK Addendum.
Annex II: Technical and Organizational Security Measures
See Security Policy.
Execution
Provider and Customer have not changed the DPA Standard Terms except for the details on this page. By executing this DPA, each party agrees to its terms as of the date of signature.
To execute this Data Processing Agreement, contact us at legal@contextflo.com.
This DPA incorporates by reference the Common Paper Data Processing Agreement (Version 1.1), which is free to use under CC BY 4.0.