Data Processing Addendum

This Data Processing Addendum ("DPA") forms part of the AllMCP Terms of Service (the "Agreement") between Perception Dynamics Inc. ("AllMCP", "we") and the customer that accepts the Agreement ("Customer", "you"). It applies whenever we process personal data on your behalf while providing AllMCP — the MCP endpoint at https://go.allmcp.co/mcp/ (the "Service"). By accepting the Agreement, you accept this DPA. No signature is required; if you need a countersigned copy, email privacy@allmcp.co.

Terms like "personal data", "controller", "processor", "data subject", and "supervisory authority" have the meanings given in the GDPR (EU 2016/679) and, where applicable, the UK GDPR.

1. Parties and roles

• You are the controller; we are the processor. For personal data that transits the Service on your behalf — tool-call content, your end-users' identifiers, and the credentials you connect — you decide the purposes and means; we process only on your instructions.
• If you are yourself a processor for your own clients, we act as your subprocessor, and you warrant that your controller's instructions permit our processing as described here.
• For your own account data (your sign-in email and OAuth identity), we are an independent controller; that processing is covered by our Privacy Policy at /legal/privacy, not this DPA.

2. Subject matter and duration

The subject matter is the processing described in Annex 1. This DPA lasts as long as the Agreement, plus the short deletion window in Section 10.

3. Nature and purpose of processing

The Service is a relay. Your AI agent sends a tool call; we forward it to the SaaS provider you connected (Bitrix24, Google Sheets, AmoCRM, YouGile, SalesDrive, Binotel, Google Ads, Altegio, and others); the provider's response returns to your agent. Concretely, we:

• relay tool calls and responses between your agent and your connected providers — the content of those calls exists in our systems in memory only, for the duration of the request, and is not stored;
• store the credentials you connect (provider OAuth tokens and API keys), encrypted at rest with AES-256-GCM, and use them solely to serve your own tool calls;
• record usage metadata for operation, security, and quota metering: client/organization/user identifiers, provider, tool name, duration, and status. No CRM records, spreadsheet contents, or messages are persisted. One honest caveat: when a provider returns an error, we store the upstream error string truncated to 1,000 characters, which may quote fragments of the provider's error text.

4. Categories of data subjects and personal data

Data subjects: your authorized users (the people whose agents call the Service) and the business contacts of yours whose data transits tool calls — for example, contacts in a CRM your agent reads or writes.

Personal data:

• pseudonymous organization and user identifiers you pass in requests;
• provider credentials you connect (stored encrypted);
• usage metadata as described in Section 3;
• transient tool-call content — whatever personal data your connected providers return (names, emails, phone numbers, CRM records), held in memory only during the request and never persisted.

We do not require and ask you not to route special-category data (Art. 9 GDPR) through the Service unless your use case and your providers' terms lawfully support it; if you do, it transits under the same never-stored model.

5. Documented instructions

We process personal data only on your documented instructions: this DPA, the Agreement, your configuration of the Service, and the tool calls your agents send (each call is an instruction). We will not process it for our own purposes. If we believe an instruction violates data protection law, we will tell you and may pause the affected processing. If law requires us to process otherwise, we will inform you before doing so unless the law forbids it.

6. Confidentiality

Everyone we authorize to process your personal data is bound by confidentiality obligations (contract or statute) and receives access only as needed to operate the Service.

7. Security

We implement the technical and organizational measures in Annex 2, including AES-256-GCM encryption of stored credentials, TLS 1.2+ in transit, no-payload logging, and tenant isolation. We may improve these measures over time but will not materially degrade them during the term. The living, more detailed description is at /security.

8. Subprocessors

You give general authorization for the subprocessors listed at /legal/subprocessors (currently: AWS for hosting in the United States; Google and GitHub as sign-in relays; Sentry for error events scrubbed of tokens, keys, and PII; Resend for transactional email when enabled; Vercel for the web frontend and API proxy; GitBook for public docs only — no customer data). We will update that page at least 30 days before adding a subprocessor that processes your personal data and offer a way to be notified. If you object on reasonable data-protection grounds, we will work with you in good faith; if we cannot resolve it, you may terminate the affected Service with a pro-rata refund of prepaid, unused fees. We impose data-protection obligations on each subprocessor no less protective than this DPA and remain liable for their performance.

9. International transfers

We host on AWS in the United States. For transfers of EEA personal data, the EU Standard Contractual Clauses (Commission Decision 2021/914) are incorporated by reference — Module 2 (controller → processor) or Module 3 (processor → processor), as applicable — with you as data exporter and Perception Dynamics Inc. as data importer; Annexes 1 and 2 of this DPA serve as the SCC annexes. For UK transfers, the UK International Data Transfer Addendum to the SCCs applies.

10. Deletion and return

You can delete data yourself at any time: revoking a connector or deleting your account kills API keys and connector grants immediately. On account deletion or termination, we hard-purge stored personal data after a 7-day grace window (a cancellation link is emailed in case the deletion was accidental). Usage logs are pseudonymized — user and organization references nulled — and retained for accounting for 24 months. On written request, we will confirm deletion in writing. Because we never store tool-call content, there is no content to return; credentials are yours to re-create with your providers and are purged, not returned.

11. Assistance to you

Taking into account the nature of the processing, we will assist you with reasonable measures:

• Data subject requests. If a data subject contacts us directly about your data, we will redirect them to you and, on request, help you respond using the tools available (deletion, pseudonymization, export of usage metadata). Since we hold no content, most requests will be actionable only in your connected providers.
• Articles 32–36. We will provide reasonable information to support your security assessments, DPIAs, and consultations with supervisory authorities.

12. Personal data breach

We will notify you without undue delay, and in any event within 72 hours, of becoming aware of a personal data breach affecting your personal data, at your account email, with what we know: nature of the breach, categories and approximate volumes affected, likely consequences, and measures taken or proposed. We will keep you updated as the investigation progresses. Our notice is not an admission of fault.

13. Audits

We support audits information-first: we will answer reasonable security questionnaires and provide available documentation and reports (see /security). If those genuinely do not satisfy a legal requirement, you may conduct (directly or via an independent auditor bound by confidentiality) an audit no more than once per 12 months, on 30 days' notice, during business hours, without disrupting the Service, and at your cost. Audits may not access other customers' data.

14. Liability and order of precedence

Each party's liability under this DPA is subject to the limitations and exclusions of liability in the Agreement; this DPA does not create a separate or additional liability cap. If this DPA conflicts with the Agreement, this DPA controls for data-protection matters; if the SCCs conflict with either, the SCCs control.

Annex 1 — Details of processing

Annex 2 — Technical and organizational measures (summary)

Living version: /security. Highlights, all verified in our codebase:

• Encryption: provider credentials encrypted at rest with AES-256-GCM; TLS 1.2+ for all data in transit.
• No-payload logging: tool-call content is never persisted; logs contain metadata only (plus upstream error strings truncated to 1,000 characters).
• Credential hygiene: API keys stored as SHA-256 hashes only (raw value shown once); provider credentials never logged.
• Authentication: passwordless only (Google/GitHub sign-in) — no passwords ever created or stored; connector access via revocable OAuth 2.1 tokens (revocation immediate for new refreshes, ≤60 minutes for outstanding access tokens).
• Tenant isolation: Client → Organization → User hierarchy with per-user credentials; in-VPC cache.
• Error tracking: Sentry events scrubbed of tokens, keys, and PII by an extended denylist scrubber.
• Hosting: AWS, United States.

Questions about this DPA: privacy@allmcp.co. Security reports: security@allmcp.co.