Data Processing Agreement

A Data Processing Agreement (DPA) is a contractual arrangement that governs how AluminatAI processes personal data on your behalf. It is required under:

• GDPR (EU General Data Protection Regulation, Article 28) for customers in the EEA or processing EEA data
• UK GDPR for customers in the United Kingdom
• Many enterprise procurement and legal review processes, regardless of jurisdiction

Our DPA incorporates the EU Standard Contractual Clauses (SCC) adopted by the European Commission in June 2021 (Decision 2021/914), and covers data transfers from the EEA to the United States.

• Subject matter and duration of data processing
• Nature and purpose of processing (GPU telemetry monitoring, cost attribution, reporting)
• Type of personal data processed (see our Privacy Policy)
• Categories of data subjects (your employees and contractors operating GPU infrastructure)
• AluminatAI's obligations as data processor
• Your obligations as data controller
• Sub-processor list and change notification procedure
• Security measures (Technical and Organizational Measures)
• Data subject rights assistance
• Breach notification obligations (72-hour GDPR timeline)
• Data deletion and return on contract termination
• EU Standard Contractual Clauses (Module 2: Controller-to-Processor)

DPAs are available to all AluminatAI customers at no additional cost. To request a DPA:

1. Email us at the address below with subject line: "DPA Request — [Your Company Name]"
2. Include your company's legal name, registered address, and contact name
3. We will send you a pre-signed DPA within 2 business days
4. You review, countersign, and return a copy — that's it

Our DPA includes our current list of sub-processors. We notify customers of any material sub-processor changes with at least 14 days' notice, giving you the opportunity to object.

For privacy and compliance questions, contact our privacy team at privacy@aluminatiai.com. For enterprise contract and legal inquiries, email legal@aluminatiai.com.