Legal & trust

Data processing agreement

Effective 2026-10-13 · version 1.1

Standard text for Free and Starter, accepted with the terms of service. Corporate customers can negotiate a separate DPA.

1. Parties and scope

This Data Processing Agreement (DPA) is between the customer who accepted the terms of service (the Controller) and Thalius AI AB, organisation number 559528-5635, VAT SE559528563501, Stockholm, Sweden (the Processor). It applies when the Processor processes personal data on the Controller's behalf while providing the Thalius Hippocampus cloud service (the Service), and it meets Article 28 of Regulation (EU) 2016/679 (GDPR).

If this DPA and the terms of service conflict on data protection, this DPA prevails.

2. Details of the processing

3. Processor obligations

The Processor:

1. processes personal data only on the Controller's documented instructions: the terms, this DPA, and the Controller's configuration of the Service. If an instruction appears to break data protection law, the Processor says so;
2. makes sure that everyone with access to the data is bound by confidentiality;
3. applies the technical and organisational measures in Annex 1;
4. uses sub-processors only as set out in section 5;
5. helps the Controller answer data subject requests, mainly through the Service's own functions for export, correction and deletion;
6. helps the Controller with security, breach notification, impact assessments and prior consultation, taking into account the nature of the processing;
7. deletes or returns personal data at the end of the Service as set out in section 10;
8. provides the information needed to demonstrate compliance, and allows audits as set out in section 8.

The Processor does not use Customer personal data to train AI models and does not sell it.

4. Controller obligations

The Controller is responsible for having a lawful basis for the data it uploads, for informing data subjects, for configuring access within its tenant, and for not uploading data it may not process.

5. Sub-processors

• The Controller gives general authorisation for the sub-processors listed on the sub-processors page.
• The Processor announces new or replacement sub-processors on that page, and by email to tenant administrators, at least 30 days before they apply.
• The Controller may object on reasonable data protection grounds within that period. If no solution is found, the Controller may terminate the affected Service and receive a refund of prepaid fees for the unused whole months.
• The Processor imposes data protection obligations on each sub-processor that are equivalent to this DPA, and remains liable for them.

6. International transfers

Documents and the knowledge structure are stored in the EU (Finland). Where a sub-processor processes personal data outside the EU/EEA, the transfer relies on an adequacy decision (including the EU–US Data Privacy Framework for certified providers) or on the Standard Contractual Clauses (Commission Decision 2021/914, Module 3), supported by a transfer risk assessment. Corporate customers can require EU-hosted or customer-hosted inference so that no transfer takes place.

7. Personal data breaches

The Processor notifies the Controller without undue delay, and no later than 72 hours after becoming aware of a personal data breach affecting the Controller's data. The notice includes what is known about the nature of the breach, the categories and approximate numbers involved, likely consequences, and the measures taken or proposed. Further information follows as it becomes available.

8. Audits

The Processor makes available on request its security documentation, sub-processor list and the results of any third-party assessments. If those are not enough, the Controller may audit, itself or through an independent auditor bound by confidentiality, once a year with 30 days' notice, at its own cost, in a way that does not compromise other customers' data.

9. Liability

Liability under this DPA follows the limitations in the terms of service, except where the GDPR does not allow them.

10. Deletion and return

• The Controller can export its knowledge base as Markdown, and delete documents, at any time. Deleting a source document deletes everything derived from it across the vault, index and graph.
• The Controller should export what it needs before the Service ends; no export is provided after termination.
• When the Service ends, the Processor deletes the Controller's personal data from active systems within 30 days and from backups within 90 days, unless EU or Member State law requires it to be kept.
• On request, the Processor confirms the deletion in writing.

11. Governing law

This DPA is governed by Swedish law, and disputes are settled as set out in the terms of service.

Annex 1 — Technical and organisational measures

Encryption

• Each document is encrypted with its own key (XChaCha20-Poly1305), bound to the tenant and document identity and wrapped in a cloud key management service. The root key never leaves the KMS.
• The storage layer holds ciphertext only. Decryption happens inside the document vault, per request.
• TLS protects all data in transit.

Tenant isolation and access control

• The tenant identity is bound into every encryption operation, so data cannot be decrypted under another tenant.
• Permissions are enforced inside the retrieval layer, so results a user may not read are filtered out before ranking.
• Folder and document grants, groups and inheritance, and per-user isolation within a shared workspace.
• Password and magic-link sign-in on Free and Starter, SAML/OIDC single sign-on on Corporate. Sessions are cryptographically verified at the application edge.

Logging and monitoring

• Security-relevant vault operations are sequence-logged, with gap monitoring.
• Every answer resolves to a byte range in a named source, so access can be traced at passage level.

Operator access

• Infrastructure operators cannot bypass authorisation.
• Access to customer data is need-to-know, for support the customer asks for or for security.

Minimisation towards model providers

• Model providers receive only the fragments needed for a request, transiently, and have no way to decrypt stored data.

Resilience and deletion

• Derived data can be rebuilt from source documents. Deletion cascades from source documents to everything derived from them.

Organisational measures

• Confidentiality undertakings for staff and contractors, a documented incident response procedure, and due diligence on sub-processors.

Known open items

• A third-party security review is not yet commissioned.
• The derived knowledge layer is moving under the same encryption boundary as source documents.
• Conversation logs are not yet pinned to the EU.

Annex 2 — Sub-processors

The current list, with stage, region and the data each one processes, is on the sub-processors page and forms part of this DPA.