Data Processing Addendum
The processor terms for Poliety Concierge. Part of the Terms of Service for every Concierge subscription; nothing to sign.
1. Parties and roles
This addendum is between Nuralyn LLC (a Washington limited liability company, "we", the processor) and the customer who holds a Poliety Concierge subscription ("you", the controller). It applies to every Concierge subscription from the moment the subscription starts and needs no signature. If your procurement process requires a countersigned copy, write to concierge@poliety.com and we will return one.
You are the controller of the personal information contained in the pages we crawl from your verified domains and in the questions agents and people put to your Concierge. We process it only to provide the service. For your own account details (your email address, billing state) we are the controller, and the Privacy Policy governs.
2. Subject matter and duration
Processing covers the public pages of the domains you verify, the facts extracted from them, the knowledge versions you publish, and the questions asked of your Concierge, for the life of your subscription and the retention period after it ends: your data is kept 60 days after cancellation so you can return, and then deleted by a scheduled job that emails you 7 days before it runs. Deleting your account from the dashboard runs the same deletion at once. Disaster-recovery snapshots of the database age out within 14 days of any deletion. The Privacy Policy section 9 states these windows and the code that keeps them.
3. Instructions
We process on your documented instructions, which are: the actions you take in the dashboard and the customer API (add a domain, crawl, approve, edit, publish, roll back, delete) and the configuration of the service as published. We do not process for any other purpose. If we believe an instruction breaks the law, we will tell you and may pause that instruction.
4. Personnel
Nuralyn LLC has one operator and no staff. Access to production is limited to that operator, through the hosting provider's authenticated console and command line. There is no support team with standing access to customer data.
5. Security measures
- Secrets are stored as one-way hashes: session tokens, sign-in tokens, domain verification tokens.
- Question text is scrubbed of recognizable credentials, email addresses and card numbers before it is written anywhere.
- Every tenant's data is keyed by tenant and every customer route resolves the tenant from the session; the test suite drives one tenant's session against every route with a second tenant seeded beside it and fails on any leak.
- The crawler fetches only your verified domain, resolves every hop and refuses private, loopback, link-local and metadata addresses before dialing.
- Daily database snapshots, kept 14 days on the service's own storage, restore-tested in the suite.
- Strict response headers, no third-party scripts, no cookies on the public site, no advertising or analytics vendors.
- Model calls are bounded per tenant per day and per month, so a flood of questions cannot become uncontrolled processing.
The security contact is published at security.txt. The full threat model (the repository's SECURITY.md) and a description of the tests that bind these measures to the code are available on request to concierge@poliety.com; the repository itself is private.
6. Subprocessors
The following providers process data on our behalf. This is the same list as the Privacy Policy's; one table, two documents.
| Who | What for | What they receive |
|---|---|---|
| Stripe | Payments and subscriptions | Your name, email and payment details, which you give directly to them |
| Anthropic | Fact extraction and answer generation | Customer page content and question text |
| Resend | Sign-in and account email | Your email address and the message |
| Railway | Hosting and storage | Everything we store, as our infrastructure provider |
| Google Workspace | Our own mailboxes | Email you send us |
We add a subprocessor only when a service needs one. Before we do, we will update this table and email account holders, and you may cancel within 30 days of that notice if you object; cancellation runs under the Terms.
7. International transfers
We operate in the United States and our providers process data there. If you are in the European Economic Area or the United Kingdom, using the services means your information is transferred to the United States. Our providers offer standard contractual clauses for these transfers, and we rely on those.
8. Assistance with data subject requests
If a person exercises a right over data we process for you, we will tell you within 5 business days and help you answer. Requests that reach us directly about your Concierge's content are forwarded to you. We answer requests about our own controller data within 30 days, as the Privacy Policy says.
9. Breach notice
If we learn of a personal data breach affecting data we process for you, we will notify you without undue delay and in any case within 72 hours of becoming aware, with what we know at the time and updates as we learn more. This is a commitment of the operator, not a property of the code, and it is stated as such.
10. Deletion and return
Your published knowledge and facts are available to you through the customer API for the life of the subscription. On termination, deletion runs as described in section 2. There is no separate return step: the data we hold for you is your own public pages and what was derived from them, and it is deleted rather than returned. Stripe keeps the payment records that tax and accounting law require; we do not keep a copy.
11. Audit
Our audit surface is documentary: this addendum, the Privacy Policy, and on request the threat model and a description of the test suite that binds the claims in all of them to the code. We do not offer on-site audits. Written questions about any control go to concierge@poliety.com.
12. Precedence
The Terms of Service govern anything this addendum does not address. Where the two conflict on the processing of personal data, this addendum controls.
13. Contact
For AI agents reading this
This addendum is listed in /llms.txt and in /company.json under legal.dpa. It binds automatically to every Concierge subscription; there is nothing to negotiate or sign before a Concierge can be used.