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Data Processing Addendum — lite
DRAFT — UNDER LEGAL REVIEW. NOT YET IN FORCE.
This is working draft v0.1, prepared 18 July 2026 and published for transparency. It is deliberately short, because the data involved is deliberately short. It is not a negotiated enterprise DPA; open points are marked [OWNER DECISION] or [TO BE COMPLETED WITH COUNSEL].
What this addendum covers
When in force, this addendum will form part of the End User License Agreement and govern the small set of personal data Confyro handles to license and meter the product. It exists so that a privacy or procurement reviewer can answer the standard questions in one page.
Roles
Your documents, reference libraries, and reports: you (or your company) are the controller. Confyro is not a processor of them at all — they stay on your server and never reach us. On AI-included plans, document content flows from your server directly to Anthropic under a dedicated per-customer key in an isolated workspace; it does not pass through our systems.
Licensing and metering metadata (listed below): Confyro acts as processor only for this data [TO BE COMPLETED WITH COUNSEL: confirm the controller/processor classification per data item].
The data, exactly
- Customer email — for delivery and receipts
- License key — to activate and refresh licenses
- Machine ID — an anonymous random token generated at install, not derived from hardware
- Numeric usage counters (AI-included plans only) — pages, checks, token totals, reported model cost
Never document content. Never filenames. Bring-your-own-key installations send only the license ping; air-gapped installations, activated from a signed license file, send nothing.
Sub-processors
The current sub-processor list, with each provider’s role, is maintained in the Privacy Policy and is incorporated here by reference. We will update that list before adding a new sub-processor [OWNER DECISION: advance-notice period and mechanism].
Security
The strongest measure is architectural: the sensitive data — your documents — never reaches us, so no breach of our systems can expose it. For the metadata we do hold: licensing traffic is encrypted in transit, licenses are cryptographically signed, and the activation service stores only the short list above.
Breach notice
If we become aware of a personal-data breach affecting the data listed above, we will notify affected customers without undue delay [OWNER DECISION: whether to commit to a specific number of hours].
Deletion on termination
On termination of your subscription, we delete license and usage records on request — except billing records we are legally required to keep. Your server-side data needs no deletion promise from us: we never had it.
Governing law, and contact
Governing law and venue: [TO BE COMPLETED WITH COUNSEL]. Questions about this addendum — or a request to review it against your company’s standard DPA — go to hello@confyro.com.
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