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Data Processing Addendum

How ProsGrow processes Customer Content as a processor. Draft, pending counsel.

Draft — not yet in effect. This document is a structural draft pending counsel review. It is not a binding agreement until ProsGrow publishes an executed version or it is attached to a signed order form. Section headings show the intended structure; the operative language is finalized by counsel.

Version 2026-08-02 (effective: not yet in effect).

This Data Processing Addendum supplements the Serving Terms. Operative definitions and the processing scope are set by counsel; the factual processing description below mirrors the published data-retention exhibit.

1. Definitions

Controller / processor / Customer Content / subprocessor.

2. Roles & scope of processing

ProsGrow processes Customer Content solely to generate the requested completion.

3. Data policy

Per the draft data policy, applying to every model: we do not train on your data; no durable retention — prompts and completions are processed transiently and are not durably retained after the response is returned; processing region is the United States. Metadata-only durable storage; no prompt/completion text retained. Draft — not yet in effect.

4. Subprocessors

Whether a subprocessor list is published, and what it names, is a counsel decision.

5. Security measures

Technical and organizational measures (ties to the security FAQ).

6. International transfers

Per the draft data policy, processing is in the United States for every model (draft — not yet in effect). Any international-transfer terms are set by counsel.

7. Data-subject requests & assistance

8. Breach notification

9. Audit

10. Return & deletion