This Data Processing Agreement (“DPA”) forms part of the agreement between the customer (“Controller”) and Titan Tech Development L.L.C-FZ (“Processor”, “we”) and governs the processing of personal data in connection with the HyperInfer Service. A countersigned copy is available on request.
1. Roles & definitions
The Controller determines the purposes and means of processing; the Processor processes personal data only on the Controller’s documented instructions. “Data Protection Laws” includes the UAE PDPL, the EU/UK GDPR, and CCPA/CPRA as applicable; defined terms (personal data, processing, data subject, sub-processor and the like) take their meaning from those laws. This DPA prevails over conflicting terms of the agreement on the subject of data protection.
2. Scope, nature & details
The particulars of processing are set out in Annex 1. The subject matter is the operation of single-tenant inference endpoints. The duration is the duration of each request (no persistence) and, for operational metadata, the term of the agreement. The nature and purpose are automated inference computation and the provision of the Service.
3. Processor obligations
We will:
- process personal data only on the Controller’s documented instructions (including with regard to transfers) unless required by law, in which case we notify the Controller unless legally prohibited;
- inform the Controller if, in our opinion, an instruction infringes Data Protection Laws;
- ensure that personnel authorised to process personal data are bound by confidentiality;
- implement the technical and organisational measures set out in Annex 2; and
- assist the Controller, taking into account the nature of processing, with its security, breach-notification, data-protection-impact-assessment and prior-consultation obligations.
4. Zero data retention
As a binding obligation, the Processor shall not log, store, persist, cache to disk, or otherwise retain the content of prompts, completions or any files submitted for inference. Such content exists only in volatile memory for the duration of a single request and is purged on completion. The Processor shall not use such content to train, fine-tune or evaluate any model.
This obligation is end-to-end: it binds our sub-processors, and it covers transient performance caches, abuse-prevention buffers and crash dumps alike. Any transient performance caches are disabled for zero-retention traffic; abuse-prevention signals are derived from metadata only and exclude content. No processing path — including speculative-decoding or draft-model paths — consumes or retains customer content.
5. Security measures
As set out in Annex 2 (TOMs), the Processor maintains: encryption in transit (TLS 1.3) and at rest (AES-256) for any artifacts; single-tenant compute isolation; role-based access control and least-privilege production access; SSO/SAML; audited access logging that excludes content; vulnerability management and penetration testing; and an information-security program assessed to SOC 2 Type II and ISO 27001 (both held).
6. Sub-processors
The Controller provides general authorisation for the Processor to engage the sub-processors listed in Annex 3. The Processor imposes data-protection obligations no less protective than this DPA on each sub-processor, remains liable for their performance, maintains the current list in the Trust Center, and gives at least 30 days’ notice of additions or replacements, during which the Controller may object on reasonable grounds.
7. International transfers
For personal data originating in the EEA, UK or Switzerland, the parties incorporate the EU SCCs (Module 2 controller-to-processor and Module 3 processor-to-sub-processor), the UK IDTA/Addendum, and the Swiss addendum, as set out in Annex 4. The Processor supports region pinning so that inference can be confined to a chosen data-resident region. UAE-origin transfers follow PDPL Art. 22–23. The zero-retention design is a supplementary safeguard.
8. Data-subject requests
Taking into account that the Processor does not retain inference content, the Processor will provide reasonable assistance to the Controller in responding to data-subject requests, and will promptly forward any request it receives directly to the Controller. Requests relating solely to inference content are generally not actionable after the request completes, as no such content is retained.
9. Personal-data breach
The Processor will notify the Controller without undue delay (and in any event in time to help the Controller meet its own deadlines) after becoming aware of a personal-data breach affecting the Controller’s data, with information reasonably necessary for the Controller’s notifications, and will cooperate on remediation.
10. Audit
The Processor will make available information necessary to demonstrate compliance, including SOC 2 and ISO reports under NDA and responses to reasonable security questionnaires. On-site audits, on reasonable prior notice and no more than once a year absent a breach or regulator requirement, are available as a backstop.
11. Return & deletion
Because inference content is never retained, there is none to return or delete. On termination, the Processor will delete or return remaining account and operational metadata in accordance with the agreement and applicable law, subject to legal-retention requirements.
12. CCPA/CPRA service-provider terms
The Processor is a “service provider” under the CCPA/CPRA. It will not sell or share personal information; will not retain, use, or disclose it for any purpose other than the business purpose specified in the agreement or as otherwise permitted by the CCPA; will not combine it with personal information from other sources except as permitted; will provide the same level of privacy protection required of the Controller; and will flow these restrictions down to sub-processors. The Controller may take reasonable steps to monitor compliance.
13. UAE PDPL terms
The parties will comply with the UAE PDPL as applicable. The Processor processes on the Controller’s instructions, applies appropriate safeguards to cross-border transfers, assists with data-subject rights and breach handling, and supports the Controller’s accountability obligations to the UAE Data Office.
14. Liability & precedence
Each party’s liability under this DPA is subject to the limitations of liability in the agreement; this DPA does not create uncapped liability. In case of conflict on data-protection matters, this DPA (and the SCCs, where they apply) prevail.
15. Annexes
Annex 1 — Details of processing
Categories of data subjects: the Controller’s end users and personnel. Types of personal data: as contained in the inputs the Controller chooses to send, together with account and contact data. Special categories: only if the Controller sends them — discouraged unless a BAA or other required safeguards are in place. Nature and purpose: automated inference. Duration: per request, plus the term of the agreement for operational metadata.
Annex 2 — Technical & organisational measures
As described in Section 5, comprising encryption in transit and at rest, single-tenant compute isolation, role-based and least-privilege access control, SSO/SAML, content-excluding access logging, and vulnerability management and penetration testing. The full control list is enumerated on request.
Annex 3 — Sub-processors
Aligned to the Trust Center list, which is the single source of truth shared by /trust and this DPA:
- Amazon Web Services, Google Cloud, Microsoft Azure — cloud infrastructure;
- Cloudflare — edge and DDoS protection;
- Datadog — metadata observability (US/EU).
Annex 4 — Transfer mechanisms
SCC module elections (Module 2 and Module 3), the UK Addendum, the Swiss addendum, and a docking clause for the accession of further parties.