Data processing agreement

This is a draft. A lawyer reviews it before anyone outside our own sites can sign up, and it may change in that review. Notes for the review are marked "For the review".

This agreement is part of the terms of service between the operator of Flash staging ("we", the processor) and the partner ("you", the controller). It covers the personal data we process for you when your site uses Flash staging.

For the review: the parties' legal names, the governing law, and the standard contractual clauses where they are needed.

What we process, and why

We process personal data only to run Flash staging for your site: to deliver messages between visitors and the people behind your profiles, to let an AI assistant reply for an owner who allows it, and to keep the service safe.

• Whose data: visitors who write to your profiles, the owners of your profiles, and your staff who use the partner console.
• What data: messages and their times; the profiles you send us, without the values of private fields; a fingerprint of each user id your user tokens carry, and the names they carry; a fingerprint of each owner's user id; owners' availability, working hours and instructions; blocks; your staff's work email addresses and roles.
• What we do with it: store it, deliver it, show it to the people in the conversation, and send a conversation and its profile's public and AI-only fields to the AI model when the AI assistant replies.
• For how long: while you use Flash staging, within the retention periods below.

We do not process the values of private profile fields at all: we drop them as they arrive.

Our obligations

• We process the data only on your documented instructions: these terms, the settings you choose in the partner console, and the requests your systems send.
• Everyone on our side who can reach the data is bound to confidentiality, and staff reach a conversation only for support, abuse or legal reasons. Each such read is recorded in an audit log.
• We protect the data with the measures listed below.
• We help you answer requests from the people whose data it is, and with data protection impact assessments where you need our part.
• We tell you without undue delay after we learn of a personal data breach that affects your data. For the review: a maximum number of hours.
• For the review: how your data is deleted when these terms end, whether you may ask for a copy first, and in what form. Flash staging does not yet delete a partner's data on its own, and a deleted record stays in backups for their retention below.
• We give you the information you need to show that we keep this agreement, and allow audits on reasonable notice. For the review: the terms of audits.

Security measures

• Flash staging runs on servers of its own, shared with no other service. No data passes between it and any other.
• Every connection to Flash staging from outside is encrypted.
• Each partner's data is kept apart by the database itself, with row-level security, as well as by our code. A session your user token opens reaches only your data.
• Secret keys are stored as hashes. Staff sign in with a password and a security key.
• Logs and traces never contain message text, names, email addresses, phone numbers or tokens. Our web servers' access logs cut client addresses to their network. For the review: the sign-in service's logs still keep the full address and browser of each request your staff make to it.
• Every AI message carries the AI assistant's label; private profile fields never reach the model.
• Database backups are encrypted before they leave the server, and kept for about four to five weeks. The backup store keeps a replaced copy for at least as long again.

Retention

• Records of AI replies, with what the AI assistant read for each: 90 days, unless the operator sets another period for Flash staging.
• Messages and conversations: for the review. Flash staging does not yet delete them on its own.
• Backups: about four to five weeks, and a replaced copy for at least as long again in the backup store. For the review: that period.

Sub-processors

We tell you before we add or replace a sub-processor, and you may object.

Draft of 24 October 2026.