Data Processing Agreement

Last updated: October 14, 2026

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Data Processing Agreement

1. Introduction

1.1 Scope

This Data Processing Agreement ("DPA") forms part of the Terms of Service between you (the "Customer") and Kool Labs ("Kool") and applies where Kool processes personal data on your behalf in providing the Services.

1.2 Roles

For personal data contained in Your Content, the Customer is the controller and Kool is the processor. Kool acts as controller for account, billing and usage data as described in our Privacy Policy.

2. Processing

2.1 Instructions

Kool will process personal data only on the Customer's documented instructions, which include these Terms, this DPA and the Customer's use of the Services, unless law requires otherwise.

2.2 Confidentiality

Kool ensures that people authorized to process personal data are bound by confidentiality obligations.

2.3 Security

Kool maintains appropriate technical and organizational measures, including encryption in transit and access controls, to protect personal data.

3. Subprocessors and Transfers

3.1 Subprocessors

The Customer authorizes Kool to engage subprocessors, such as cloud hosting and AI model providers, under written terms that provide equivalent data protection. Kool remains responsible for their performance.

3.2 International Transfers

Where personal data is transferred outside its region of origin, Kool relies on approved safeguards such as standard contractual clauses.

4. Assistance and Deletion

4.1 Assistance

Kool will reasonably assist the Customer in responding to data subject requests and in meeting its security, breach notification and impact assessment obligations, and will notify the Customer without undue delay of a personal data breach.

4.2 Return and Deletion

On termination, Kool will delete or return personal data within a reasonable period, except where retention is required by law.

4.3 Audits

Kool will make available the information reasonably necessary to demonstrate compliance with this DPA and allow for reasonable audits.

5. Contact

5.1 Questions

To request a signed copy of this DPA or ask questions, contact [email protected].

© Kool Labs 2026