Data processing agreement (Studio teams)
Version 1.0. Effective [EFFECTIVE_DATE]. Words in square brackets are placeholders.
This agreement meets Article 28 of the GDPR (Regulation (EU) 2016/679). It is part of the terms of service. It applies to every business customer with a Studio workspace, from the day the workspace is made. No signature is needed. A customer who needs a signed copy writes to legal@plintus.ai, and we send one.
1. Parties and roles
- The customer is the business that holds the workspace. For personal data in the workspace, the customer is the controller. In this agreement it is “you”.
- plintus is [COMPANY_NAME], [COMPANY_FORM], Krivių g. 5, 01204 Vilnius. For the same data, plintus is the processor. In this agreement it is “we”.
For account data, billing data and security logs of the people who use plintus, we are a controller ourselves. The privacy policy covers that. This agreement covers only the workspace data in section 2.
2. What we process
Subject. We run the plintus service for you, as the terms say.
Length. As long as the workspace exists, plus the time to delete it (section 10).
Nature and purpose. Storing, showing, changing, sharing and exporting your rooms and designs. Scanning rooms. Making pictures and models. Answering assistant requests. Making backups. Sending email about your workspace.
Types of personal data. Photos and video of homes and offices, which can show people or personal items. Names and email addresses of your team and clients. Comments. Names that guests type when they comment or approve. Design data.
People concerned. Your team members and clients. Your clients’ household members and other people who appear in photos.
We do not process special categories of data (Article 9) on purpose. If your photos show them by chance, we treat them the same way, and we do not look for them.
3. Your instructions
We process the data only on your written instructions. This agreement, the terms and what you do in the app are your instructions. We tell you if we think an instruction breaks data protection law. We may refuse it until you confirm or change it.
We do not use workspace data for our own ends. We do not use it to train AI models. We do not sell it or share it for advertising.
4. Confidentiality
Everyone at plintus who can reach workspace data is bound to secrecy, in a contract or by law. Only people who need access for their job get access. Staff tools run on a private network, need a second sign-in step, and log each action.
5. Security
We use the measures in annex 2. We check them and improve them as risks change. We do not make them weaker during the term.
6. Help with your duties
We help you, with the means we have, to:
- answer requests from people about their rights. Our app has export and delete tools. If a person writes to us about their data in your workspace, we pass the request to you within 5 working days. We do not answer it ourselves, unless you tell us to;
- do a data protection impact assessment and talk to an authority, when it concerns our processing;
- meet your security and breach duties (section 8).
If help takes more than a small amount of work, we may ask for a fair price, and we tell you first.
7. Subprocessors
You allow us to use the subprocessors in subprocessors.md as they are on the effective date.
- We tell you by email at least 30 days before a new subprocessor, or a change in one’s task or region, touches your workspace data.
- You can object in writing within that time, with a reason that has to do with data protection. We then look for a way to serve you without it. If we cannot, you can end the workspace plan at the end of the notice time, and we refund the unused part of what you paid.
- We sign a contract with each subprocessor. It has the same duties as this agreement. We stay liable to you for it.
8. Personal data breach
We tell you without undue delay, and within 48 hours of our learning of it, if a breach affects your workspace data. We say what we know: what happened, what data and how many people, the likely effects, and what we do. We send more as we learn it. We help you tell the authority and the people, if you must.
9. Moves outside the EU
We keep workspace data at rest in the EU. Some processing happens outside the EU, or by companies with a parent in a third country. They are marked in subprocessors.md (for example the assistant, which Anthropic runs in the US or worldwide).
For these moves we use the standard contractual clauses of the European Commission (Decision (EU) 2021/914) or the EU-US Data Privacy Framework where the company takes part. Where the clauses are needed between you and us, they apply with this agreement. Module two (controller to processor) governs you and us. Module three (processor to processor) governs us and our subprocessors. The law of Lithuania is the governing law, and its courts decide. The details of annexes 1 to 3 below fill the clauses.
For customers who need EU-only processing for the assistant, we offer a second route through the EU region of Google Vertex AI when it is ready. Ask us at legal@plintus.ai.
10. Return and deletion
You can export all workspace data at any time, in settings, as JSON and the original files in a zip.
When the workspace ends, or when you ask, we delete the workspace data. Files go within 7 days. Backups age out within 30 days. Then we delete it, unless the law makes us keep it. In that case we keep only what the law says, and we keep it safe and away from other uses.
Invoices and payment records are ours as a controller, for accounting law. They stay.
11. Proof and audits
On request we give you the information you need to check that we follow this agreement: our description of measures (annex 2), our subprocessor checks, and the results of security tests we choose to share. We answer reasonable questionnaires. You can audit us, or have an auditor audit us, once a year, with 30 days’ notice, in working hours, without disturbing other customers, and under a duty of secrecy. You pay your own costs. If an authority asks for an audit, we take part.
12. Liability
Liability under this agreement follows the liability clause in the terms, section 14. Nothing here limits what the law does not allow us to limit, or the rights of the people whose data it is.
13. Term and changes
This agreement lasts as long as we process workspace data for you. If the law or an authority changes what is needed, or we add a subprocessor, we change it by notice as in section 7 of this agreement, and section 16 of the terms. If this agreement and the terms differ on personal data, this agreement wins.
Annex 1: description of the processing
| Item | Description |
|---|---|
| Controller | The customer |
| Processor | [COMPANY_NAME] |
| Contact at plintus | privacy@plintus.ai |
| Data subjects | Customer’s team, clients, guests, people in photos |
| Data | Photos, video, rooms, designs, comments, names, email addresses, assistant questions |
| Special categories | None on purpose |
| Frequency | Continuous, while the workspace is in use |
| Retention | As in section 10 |
| Subprocessors | subprocessors.md |
| Supervisory authority (for the clauses) | [SUPERVISORY_AUTHORITY] |
Annex 2: security measures
| Area | What we do |
|---|---|
| Where data is | Data at rest in the EU (Germany, Finland). Files in object storage, under content hashes, read only through links that expire |
| Encryption | In transit with TLS. At rest with the provider’s disk and bucket encryption |
| Access control | One rule function decides all access. Roles: owner, admin, editor, commenter, viewer. Share links give view or comment access only |
| Sign-in | Auth0 with social sign-in or email and password. Sessions use an HttpOnly, Secure cookie. Staff sign in with a second step |
| Staff access | Staff tools work only on a private network and for named staff. Every action goes into an audit log |
| Separation | Each workspace’s files and rows are separate. A test checks that every table with personal data is covered by export and delete |
| Data removal | Location and hidden data are stripped from uploads. Logs hold no emails or images and are kept 30 days |
| Backups | Daily. Kept 30 days. A restore is tested every month |
| Resilience | Servers monitored. Alerts reach the owner. 99.5 percent uptime target |
| Software | Code reviewed. Tests and a boundary check run on every change. Dependencies updated. Security review before launch |
| Vendors | Contracts, EU processing, no training on our data |
| People | Secrecy duty for all who touch data. Few people have access |
| Incidents | A written plan. Breach notice to you within 48 hours |
Annex 3: subprocessors
See subprocessors.md. That file is part of this agreement.