Legal CenterData Processing AgreementUpdated January 9, 2026

Data Processing Agreement

Our data processing terms for customers and regulated environments.

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Key commitments
What you can expect from us across all legal policies.

Transparency

Plain-language policies and clear subprocessors.

Data minimization

Only the data we need to operate the service, nothing more.

Control

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Data Processing Agreement
Full policy text for your records.
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Effective Date: January 9, 2026

This Data Processing Agreement ("DPA") is entered into between Snapcircle Limited, The Gates, Beacon South Quarter, Dublin 18, Ireland ("Processor" or "we") and the customer entity that uses the Service ("Controller" or "you"). This DPA forms part of the Terms of Service and applies when we process personal data on your behalf.

If you need a signed copy, contact privacy@inqry.ai.

1. Definitions

  • Controller: The entity that determines the purposes and means of processing personal data.
  • Processor: The entity that processes personal data on behalf of the Controller.
  • Customer Data: Personal data submitted to the Service by or on behalf of the Controller.
  • Subprocessor: A third party engaged by Processor to process Customer Data.

2. Scope of Processing

We process Customer Data to provide the Service. Processing includes hosting, storage, retrieval, and AI-assisted responses based on the data you provide.

Categories of data subjects: your employees, agents, contractors, and end users.

Categories of personal data: identifiers (names, emails), usage data, and content you upload or collect via the Service.

3. Processing Instructions

We will process Customer Data only on your documented instructions, as necessary to provide the Service, or as required by law. You are responsible for ensuring you have a lawful basis to provide Customer Data to us.

4. Confidentiality

We ensure that persons authorized to process Customer Data are subject to appropriate confidentiality obligations.

5. Security Measures

We maintain reasonable technical and organizational measures to protect Customer Data, including encryption in transit, access controls, and monitoring. More details may be provided upon request.

6. Subprocessors

We may engage subprocessors to support the Service. A list of current subprocessors is available at /legal/subprocessors. We will provide notice of new subprocessors by updating that page.

7. International Transfers

Where Customer Data is transferred outside the EEA/UK, we use appropriate safeguards such as Standard Contractual Clauses (SCCs) and/or the EU-US Data Privacy Framework (DPF), where applicable.

8. Assistance

We will provide reasonable assistance to help you respond to data subject requests, taking into account the nature of processing and information available to us.

9. Data Retention and Deletion

Upon termination of the Service, we will provide a reasonable period for you to export Customer Data. After that, we will delete or anonymize Customer Data in accordance with our retention practices and legal obligations.

10. Audits

Upon written request, we will provide reasonable information to demonstrate compliance with this DPA. In-person audits are not required unless mandated by law, and any audit will be limited, scheduled with reasonable notice, and performed at your expense.

11. Liability

This DPA is subject to the limitations of liability and other terms in the Terms of Service.

12. Governing Law

This DPA is governed by the laws of Ireland.