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Data processing agreement (DPA)

Last updated: September 2026 · Digital Genics · Digital Genics
This is a template for information and does not constitute legal advice. Have it reviewed and completed by a lawyer and fill in the exact company details (entity, address, VAT) before publishing. Under Belgian and EU law, liability cannot be fully excluded.

This data processing agreement (“DPA”) forms part of the agreement between the customer (“Controller”) and Digital Genics (“Processor”) for the use of HeyOtto, and governs the processing of personal data in accordance with Article 28 GDPR.

Subject matterInstructionsConfidentiality SecuritySubprocessorsTransfer AssistanceData breachesEndAudit

1. Subject matter, duration, nature and purpose

The Processor processes personal data solely to provide the HeyOtto service: categorising incoming email and preparing draft replies and tasks. The processing lasts for the duration of the agreement. HeyOtto never sends email itself.

Categories of data subjects and data

  • Data subjects: the customer's staff and their correspondents.
  • Data: name and email address, the content of emails and drafts, and related tasks and metadata.

2. Processing on instructions

The Processor processes the data solely on documented instructions from the Controller, as set out in the agreement and the settings in the app (including the training opt-in, which is off by default). The Processor does not use the data for its own purposes.

3. Confidentiality

Persons with access to the data are bound by confidentiality. Access is limited to what is necessary to provide and support the service.

4. Security measures (TOMs)

The Processor takes appropriate technical and organisational measures, including:

  • Encryption of data in transit (TLS) and of sensitive tokens at rest;
  • Strict access control, role-based permissions and logical separation per organisation (multi-tenant);
  • Minimal OAuth permissions — read and draft, never send;
  • Logging, monitoring and error recording for security purposes;
  • Backups and recovery procedures;
  • Processing within the EU.

5. Sub-processors

The Controller grants general authorisation for the engagement of the subprocessors listed below. The Processor informs in advance of any changes, so that an objection is possible.

Sub-processorPurposeLocation
AnthropicAI model for categorising and draftsProcessing in accordance with API terms; does not train on customer data
MicrosoftMicrosoft 365 / Graph (if you connect this)EU
GoogleGmail (if you connect this)EU
[Hostingpartner]Hosting and databaseEU
[Betaalpartner]Subscriptions and billingEU/EEA

6. International transfers

Data is in principle processed within the EU/EEA. If a transfer to a third country is necessary, this takes place with appropriate safeguards (such as the European Commission's standard contractual clauses).

7. Assistance to the Controller

The Processor assists, to the extent reasonable, with responding to data subject requests and with obligations relating to security, data protection impact assessments and prior consultation.

8. Data breaches

The Processor reports a personal data breach without undue delay after becoming aware of it, with the information necessary to comply with the notification obligation.

9. Return and deletion

At the end of the service, the Processor deletes the personal data or returns it, at the Controller's choice, subject to statutory retention obligations. HeyOtto provides a data export and a deletion function for this purpose.

10. Audits

The Processor makes available the information necessary to demonstrate compliance with Article 28 GDPR, and cooperates with reasonable audits.

Questions about this text or your data? Email privacy@heyotto.eu. HeyOtto is a product of Digital Genics.

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