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This agreement covers the personal data we process for you when you use okayo. It sits alongside the Terms of Service. [COUNSEL: whether this page is the executed DPA or a summary of a signed document, and the Standard Contractual Clauses to annex]
1. Who is who
You (the customer) are the controller: you decide which brands exist, what goes into them, which accounts are connected and what gets published. We — [COUNSEL: registered company name and legal form], [COUNSEL: company registration number] — are the processor, acting on your instructions.
Your instructions are: these terms, your settings in the product, and what you and your team ask the agent to do. We do not process your brand data for our own purposes.
2. What we process, and about whom
Categories of data:
- Your team's account data — names, email addresses, roles and sign-in state.
- Brand material — brand instructions, voice and style notes, products, uploaded files and reference images.
- Content — chat sessions, drafts, campaigns, schedules, workflows and their runs, and generated text, images and video.
- Website content we crawl from the brand address you give us at onboarding.
- Connected-account data — account identities, posts published, metrics returned, and inbound comments, mentions and messages, which may contain personal data about the people who wrote them.
- Email data — recipient addresses you supply, the emails sent, and replies received at a brand inbound address.
- Memory data — the per-brand event log, embeddings derived from it, and the graph projection over it.
Data subjects: your team members, the people who engage with your brand's published content, and the people whose addresses you put on an email list.
okayo is not built for special-category data or children's data. Do not put it in.
3. Duration
We process for as long as you use the Service. Brand data is deleted when the brand is deleted or when you ask us to delete it; everything is deleted when the account is closed. Ask for an export first — see section 7.
4. What we commit to
- Process only on your instructions, unless the law requires otherwise — in which case we tell you, if we are allowed to.
- Keep the people who can reach your data under confidentiality obligations, and limit that group to those who need it.
- Maintain the security measures described in the Security Policy.
- Help you respond to a data subject's request, and to a regulator, with the information we hold.
- Tell you without undue delay if we become aware of a personal data breach affecting your data, with what we know at the time. [COUNSEL: the notification deadline to commit to, and the minimum contents of the notice]
- Delete or return your data at the end, at your choice.
5. Sub-processors
By using okayo you authorise the sub-processors below. Each processes a defined slice of your data to deliver a part of the Service.
- Clerk — sign-in, sessions, organisations and users.
- Vercel — application hosting and serverless functions, pinned to the Frankfurt region, and the AI Gateway that routes model calls.
- Neon — the managed Postgres database, EU region (Frankfurt).
- Cloudflare — R2 object storage for generated and uploaded media.
- Resend — outbound transactional and brand email, and inbound replies.
- Zernio — connecting social accounts, publishing, metrics, and inbound comments and messages.
- Luma and Seedance — image and video generation.
- DataForSEO — search and keyword data.
- Anthropic, OpenAI and Google — model providers reached through the Vercel AI Gateway, for text generation, extraction and embeddings.
- Sentry — error monitoring.
- PostHog — product analytics.
- Upstash — rate limiting.
- Stripe — payment processing, where the subscription is billed through it.
- Fly.io — hosting for the two services we run ourselves: the onboarding website crawler and the memory-graph service.
We will tell you before adding a new sub-processor, and you may object. [COUNSEL: the notice period for a new sub-processor, the objection window, and what happens if you object]
Platforms you connect yourself — a social network, a shop, a CMS — are recipients acting under their own terms with you, not our sub-processors.
6. Where the data is, and transfers
The application and the database are hosted in the EU (Frankfurt), and the memory-graph service runs in the EU. Some sub-processors above are established outside the EEA or process data there. [COUNSEL: the transfer mechanism for each non-EEA sub-processor, the SCC modules and annexes to attach, and whether a transfer impact assessment is required]
7. Helping you with data subject requests
Honest position: you can read, edit and delete brand instructions, content, drafts and connections directly in the app, and disconnect any connected account yourself. There is no self-service bulk export or account-deletion button yet. For a subject access, export or erasure request, contact us and we will do it for you. [COUNSEL: the turnaround we commit to for controller-assistance requests]
8. Audits
We will answer reasonable questions about how we process your data, in writing. We hold no third-party security certification today — we do not claim SOC 2, ISO 27001 or any equivalent, and we will not until we have one. [COUNSEL: the audit right to grant: scope, frequency, notice, cost, and what evidence we can offer instead of an on-site audit]
9. Liability
[COUNSEL: how liability under this agreement relates to the cap in the Terms of Service]
10. Contact
Data protection questions: use the contact form, or email [COUNSEL: the privacy contact address to publish].