Data Processing Agreement – CtxCore

Version 2.1 · 2026-10-11

This Data Processing Agreement ("DPA") is based on the standard contractual clauses between controllers and processors under Article 28(7) of Regulation (EU) 2016/679 (GDPR) adopted by the European Commission in Commission Implementing Decision (EU) 2021/915 of 4 June 2021 (EUR-Lex).

Structure: Part A covers conclusion of the DPA and the options chosen. Part B contains Clauses 1 to 10 in their official English wording, with the options from Part A inserted (Clause 2 prohibits changes to the Clauses). Annexes I to IV complete the Clauses. Annexes II and IV each have a part for all products and a part for each product (currently only CtxCore Brain). Part C contains additional provisions for all products that do not contradict the Clauses (Clause 2(b)). Part D contains the provisions that apply only to CtxCore Brain. Any further product gets its own part with the same structure.

Part A – Conclusion and options chosen

A.1 Parties. The controller is the customer who has signed up at account.ctxcore.io or concludes an Enterprise contract. The processor is CtxCore AB, company registration number 559560-5535, Gamla Sikforsvägen 10, 712 93 Hällefors, Sweden ("CtxCore"). Details in Annex I.

A.2 Conclusion. This DPA is concluded at sign-up by ticking the box, together with the Terms of Service. CtxCore records the account, the person, the document (dpa), the version and the time of acceptance. The customer can view this DPA at any time at https://account.ctxcore.io/legal/dpa. A signed copy is not required; on request, CtxCore issues a PDF version showing the details of the acceptance.

A.3 Term. This DPA applies for as long as CtxCore processes personal data on behalf of the customer, that is from sign-up until deletion under Part C.3.

A.4 Options chosen in the Clauses:

A.5 Order of precedence. In the event of a conflict, the Clauses (Part B) prevail over the Annexes, the Annexes over Parts C and D, and Parts C and D over the Terms of Service (Clause 4).

Part B – Standard contractual clauses

Clauses 1 to 10 of the Annex to Commission Implementing Decision (EU) 2021/915, official English version, with the options from Part A.4.

SECTION I

Clause 1 – Purpose and scope

• (a)
  The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
• (b)
  The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.
• (c)
  These Clauses apply to the processing of personal data as specified in Annex II.
• (d)
  Annexes I to IV are an integral part of the Clauses.
• (e)
  These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.
• (f)
  These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2 – Invariability of the Clauses

• (a)
  The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.
• (b)
  This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3 – Interpretation

• (a)
  Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.
• (b)
  These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.
• (c)
  These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4 – Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5 – Docking clause (optional)

Not used (Part A.4).

SECTION II – OBLIGATIONS OF THE PARTIES

Clause 6 – Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7 – Obligations of the Parties

7.1. Instructions

• (a)
  The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.
• (b)
  The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing

• (a)
  The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.
• (b)
  The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

7.6. Documentation and compliance

• (a)
  The Parties shall be able to demonstrate compliance with these Clauses.
• (b)
  The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.
• (c)
  The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.
• (d)
  The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.
• (e)
  The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7. Use of sub-processors

• (a)
  The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 30 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.
• (b)
  Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.
• (c)
  At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.
• (d)
  The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.
• (e)
  The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8. International transfers

• (a)
  Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.
• (b)
  The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8 – Assistance to the controller

• (a)
  The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.
• (b)
  The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions
• (c)
  In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

  • (1)
    the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;
  • (2)
    the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;
  • (3)
    the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;
  • (4)
    the obligations in Article 32 of Regulation (EU) 2016/679.
• (d)
  The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9 – Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

• (a)
  in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);
• (b)
  in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller’s notification, and must at least include:

  • (1)
    the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
  • (2)
    the likely consequences of the personal data breach;
  • (3)
    the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

• (c)
  in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

• (a)
  a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);
• (b)
  the details of a contact point where more information concerning the personal data breach can be obtained;
• (c)
  its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III – FINAL PROVISIONS

Clause 10 – Non-compliance with the Clauses and termination

• (a)
  Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.
• (b)
  The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

  • (1)
    the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;
  • (2)
    the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;
  • (3)
    the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.
• (c)
  The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.
• (d)
  Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

Annex I – List of parties

Controller: the customer, with the details provided at sign-up (company name, country, organisation number or VAT ID, owner of the Account as contact person). Date and version of acceptance: from the record kept in CtxCore Account.

Processor: CtxCore AB, company registration number 559560-5535, Gamla Sikforsvägen 10, 712 93 Hällefors, Sweden. Contact for data protection matters: Stefan Parge, privacy@ctxcore.io. CtxCore has not designated a data protection officer.

Annex II – Description of the processing

All products (account and billing)

Categories of data subjects

• Users of the customer (employees and persons invited by the customer)
• Persons named in the customer's content (for example colleagues mentioned in interviews, contacts in documents)

Categories of personal data

• Account and access data: name, email address, sessions
• Usage data: time and type of actions, consumption per action (for quotas and costs), technical logs

Sensitive data (Art. 9 GDPR): not intended. The customer does not bring such data into a product unless it has a legal basis for them and has agreed this with CtxCore in advance (Terms of Service, section B.5.1).

Nature of the processing: storing, sending emails (sign-in links, notifications), deletion.

Purpose: provision of the account and of the products under the Terms of Service, including the measuring of quotas.

Duration: the term of the contract, then until deletion under Part C.3 (for CtxCore Brain, see Part D.3).

Sub-processors: nature, subject matter and duration as set out in Annex IV.

CtxCore Brain

Categories of data subjects

• Users of the customer in Brain: Context Lead, Owners, Readers, interviewees

Categories of personal data

• Account and access data in Brain: role in the Context, password hash, tokens for MCP access
• Content with a personal reference: Owner assignment of Topics and Rules, history of approvals, Proposals, Flags and Conflicts (who proposed, approved or rejected what and when)
• Voice interviews: audio stream during the conversation (not stored), transcript, statements derived from it
• Uploaded documents and texts derived from them
• Chat questions and search queries

Sensitive data (Art. 9 GDPR), CtxCore Brain: voice recordings are not analysed to identify a person.

Nature of the processing: storing, organising, searching, displaying; automated processing by AI models (extracting statements, assigning Topics, comparing with existing content, finding Conflicts, drafting Rules, answering chat questions, conducting the interview); speech recognition and speech output in interviews; sending emails (invitations, sign-in links, notifications); export; deletion.

Purpose: building and maintaining the customer's company knowledge, making it available to the customer's people and AI tools.

Duration: until deletion under Part D.3.

Annex III – Technical and organisational measures

Status as of 2026-10-11. CtxCore does not promise measures that are not listed here.

Confidentiality

• Separation of customers: each Context is stored in its own database schema; access only through membership in the respective Context.
• Roles in the Context (Context Lead, Owner, Reader); write permissions per role.
• Sign-in with a password (stored only as a hash) or a one-time sign-in link sent by email; lockout after repeated failed attempts; sessions expire and can be ended.
• Access for AI tools via OAuth or personal tokens per Context; unused grants expire.
• Connections only encrypted via HTTPS (TLS).
• Communication between CtxCore Account and Brain only via HTTPS with an HMAC signature and timestamp.
• Access to the server only for CtxCore, via SSH.
• Credentials for third-party services are kept only in environment variables on the server, not in the code.
• Search engines are excluded (noindex).
• Support access to content only with time-limited approval by the customer's Context Lead; every access is logged and visible to the Context Lead (Part C.2 and Part D.2).

Integrity

• Changes to Rules go through Proposals approved by an Owner; the history remains traceable.
• Database changes only through numbered, reviewed migrations.
• Status changes and operator actions in CtxCore Account are logged.

Availability and resilience

• Daily backup of the database and a mirror of the uploaded originals and the interview transcripts. On the server, only the administrator account (root) can read the backups. A second copy goes to Amazon S3 in Frankfurt (eu-central-1): database backups are encrypted before upload with a key that is not kept on the server, and S3 encrypts all copies at rest. The server can write to this storage but cannot read the contents. Retention 14 days, on the server and in S3.
• Restores are tested in a separate test database, never directly over the live database.
• Services restart automatically after a failure; hard cost and volume limits protect against outliers.

Regular review

• Automated tests before every release; releases only from the reviewed state in version control, never from a local working copy; database backup before every release.
• CtxCore reviews these measures at least once a year and whenever the service changes significantly.

Minimisation at sub-processors

• AI models run via Amazon Bedrock with EU inference profiles, re-ranking of search results in Frankfurt (processing within the EU); no training with customer data.
• Speech recognition via Deepgram's EU endpoint, with the opt-out from Deepgram's model improvement programme.

Assistance to the controller (Clauses 8 and 9)

• Notification of personal data breaches as set out in Part A.4, with the information required by Clause 9.2.
• The customer can remove persons from a Context and edit, export or delete content itself; CtxCore assists with anything beyond that (Part C.4).

Not promised: encryption of storage media at the hosting provider, two-factor sign-in, penetration tests, certifications (such as ISO 27001 or SOC 2).

Annex IV – List of sub-processors

The current list is published at https://account.ctxcore.io/legal/subprocessors. By concluding this DPA, the customer authorises the sub-processors listed there on the day of conclusion (Clause 7.7, Option 2). CtxCore announces changes by email to the owner of the Account at least 30 days in advance and updates the list. The customer may object within this period. If CtxCore engages the new sub-processor despite the objection, the customer may terminate the contract with effect from the date of the change.

All products (account and billing)

• Hosting: Hostinger International Ltd. (section A of the list).
• Email: Amazon Web Services EMEA SARL, Amazon SES (section A of the list).
• Backups: Amazon Web Services EMEA SARL, Amazon S3 (section A of the list).

The billing provider and the other service providers in section B of the list are not sub-processors within the meaning of this Annex. The list names them for transparency.

CtxCore Brain

• AI models: Amazon Web Services EMEA SARL, Amazon Bedrock, with Claude models by Anthropic, Amazon Titan embeddings and Cohere Rerank 3.5 for sorting search results (section A of the list).
• Speech recognition: Deepgram, Inc. (section A of the list).
• Speech output: Amazon Web Services EMEA SARL, Amazon Polly (section A of the list).

Part C – Additional provisions

C.1 Instructions and default settings

C.1.1 The customer decides which content it brings into the products, who has access and which features it uses. The configuration of the products (plan, settings) and this DPA constitute documented instructions.

C.1.2 The sub-processors that the products use are set out in Annex IV. The customer instructs CtxCore to use them. CtxCore engages new providers only in accordance with the procedure in Annex IV.

C.2 No access to content without approval

C.2.1 CtxCore accesses the content of a product (for example documents, transcripts or chat) only if the customer has granted access for a limited time (for example to resolve a support request). Every such access is logged with its time; the purpose given in the approval, if any, is shown with it. Part D.2 governs the approval and the log.

C.2.2 Exempt are accesses that are necessary to avert an acute fault or threat to operation, and accesses CtxCore is legally obliged to make. CtxCore informs the customer of these without undue delay, to the extent permitted by law.

C.2.3 Automated processing by the product itself (Annex II) and the evaluation of figures without content (number, duration, costs) do not count as access to content.

C.3 Deletion and return after the end of the contract

C.3.1 Return takes place via the export function of the product (for CtxCore Brain, section B.6 of the Terms of Service). The customer can export by itself during the period set out in Part D.3.

C.3.2 After the end of the contract, CtxCore deletes the customer's data when the periods set out in Part D for each product end.

C.3.3 On request, CtxCore confirms the deletion in text form.

C.3.4 During the term, the customer deletes content itself (for example uploaded originals). Deleted content disappears from the backups after 14 days at the latest.

C.4 Assistance with data subject rights

C.4.1 The customer answers requests from data subjects. It can remove persons from the product itself and edit or delete content. Where this is not sufficient, CtxCore assists in accordance with Clause 8.

C.5 Audits

CtxCore primarily demonstrates compliance under Clause 7.6 by documentation (this DPA, the technical and organisational measures, the list of sub-processors and, on request, further information). The customer announces on-site audits at least 30 days in advance; they take place at most once in 12 months, except after a personal data breach. Each party bears its own costs of an audit.

C.6 Enterprise

For Enterprise customers, Annexes II to IV and Part C may be adapted in the Enterprise contract (for example dedicated infrastructure, different periods).

Part D – Product specifics: CtxCore Brain

This part applies only to CtxCore Brain.

D.1 Roles and instructions

D.1.1 In Brain, the customer also decides who is an Owner.

D.2 Support access and approval

D.2.1 The customer's Context Lead approves the access under C.2.1 for a limited time and can see the log of these accesses.

D.3 Periods after the end of the contract

D.3.1 Periods after the end of the trial without a plan or after the end of a paid plan:

• Days 0 to 30: paused (read and export)
• Days 30 to 60: archived (no access, reactivation on request to CtxCore)
• From day 60: CtxCore deletes the Context (database schema with all content), the uploaded original files, the interview transcripts, the memberships, the access tokens and the grants for AI tools, as well as login accounts of persons who are not members of any other Context.

D.3.2 The customer can export by itself until the end of the pause (30 days after the end of the contract).

D.4 Action log and remaining data after deletion

D.4.1 Brain's action log of the Context is deleted together with the Context. Entries in Brain's action log (type of action, time and IDs, no content) are deleted automatically after 12 months.

D.4.2 After deletion, CtxCore keeps only:

• a record that the Context was deleted, with the number of deleted items and without any content, which is deleted after 12 months;
• cost and usage figures as anonymised monthly totals, without any reference to the customer or to persons, without time limit;
• login accounts of persons as long as they are members of another Context (accounts without any other membership are deleted together with the Context);
• data that CtxCore must keep as a controller in its own right for the contract and for bookkeeping (account, invoices; see the Privacy Policy).

D.5 Persons leaving the customer's company

D.5.1 If a person leaves the customer's company, the customer decides whether that person's name remains attached to approvals and Proposals.

D.6 Employee representatives

Brain assigns approvals, Proposals, Flags and interviews to individual persons. This may constitute a technical facility suitable for monitoring behaviour or performance. It is the customer's duty as employer, before introducing Brain,

• in Germany, to involve the works council (section 87(1) no. 6 BetrVG);
• in Sweden, to negotiate with the union bound by collective agreement under section 11 MBL where the introduction is a significant change;
• in other countries, to observe the corresponding rights of employee representatives;
• to inform employees in accordance with Art. 13 GDPR.

On request, CtxCore provides a description of the features and the data stored for this purpose.

D.7 Connecting the customer's own AI tools

If the customer connects Brain via MCP or pull to an AI tool of another provider, it transfers content to that provider in its own name. That provider is not a sub-processor of CtxCore.

Terms · Privacy · Subprocessors