Huddleboard — Business Customer Data Processing Agreement
Version 2026-10-22.1 · 22 October 2026
1. Parties, scope and formation
The service provider is Michał Piontek, a sole trader registered in CEIDG, business address Jemiołuszki 118, 05-500 Zgorzała, Poland, NIP 9691453630 (Huddleboard). Privacy and contractual notices: contact@huddleboard.ai. Telephone: +48 669 967 597.
The Customer is the business identified by its authorized workspace owner in Huddleboard's online acceptance form. Huddleboard offers this standard agreement as part of its service. It supplements the service terms for personal data processed on the Customer's behalf (Customer Personal Data) and takes effect when that owner explicitly accepts it electronically. No separate signature or email exchange is required.
The acceptance record identifies the Customer's legal name and address, the covered workspace, the accepting user's identity, this document's version and digest, and the server-recorded date. The owner confirms authority to bind the Customer. The account email is the initial notice contact; the Customer may designate another contact by writing to contact@huddleboard.ai. Ordinary login, connecting a key or accepting general service terms alone does not record DPA acceptance.
The Customer is controller, or a processor acting with its controller's authority; Huddleboard is processor or subprocessor respectively. References to assisting the Customer include enabling it to assist its controller. Huddleboard's separate processing for account administration, service security and legal obligations is described in its privacy notice and is not converted into processing on the Customer's behalf by this agreement. Actual purposes determine these roles.
2. Processing instructions and Customer responsibilities
Huddleboard shall process Customer Personal Data only to provide the agreed service, on documented instructions in this agreement, the service-provider inventory in Annex C, authorized workspace operations and written requests. Instructions include access, storage, retrieval, modification, model inference, repository operations, export and erasure within the agreed scope. They do not authorize advertising, sale of Customer Personal Data or Huddleboard's training of general-purpose models on workspace content.
The Customer shall establish its lawful basis, provide necessary notices, minimize personal data, control authorized users and ensure it is entitled to issue instructions. It shall not submit special category data, criminal-offence data, payment credentials or unrelated authentication secrets unless the parties first agree specific safeguards in writing. Provider credentials may be supplied only through the designated connection controls and only where that connection is contractually permitted.
Huddleboard shall promptly inform the Customer if an instruction appears to infringe applicable data protection law and suspend the affected processing pending resolution. If Union or Member State law requires other processing, Huddleboard shall inform the Customer beforehand unless that law prohibits notification on important grounds of public interest.
3. Confidentiality and security
Huddleboard shall ensure authorized personnel are bound by confidentiality obligations and access only data needed for their duties. It shall maintain appropriate technical and organizational measures under Article 32 GDPR, including the measures in Annex B, and review them as risks and systems change. Changes shall not materially reduce the agreed protection. Customer keys must not be used for another customer, returned through ordinary settings APIs or included in model prompts or operational logs.
4. Connected services and subprocessors
The Customer may instruct Huddleboard to connect its own repository or AI-provider account. Such instructions do not themselves establish that credential custody is permitted or determine a provider's legal role. The service-provider inventory shall identify the contracting party, processing role, purpose, data, locations and applicable safeguards for each connection before its use.
Where the Customer directly engages a provider as its processor, the Customer maintains the appropriate provider agreement and Huddleboard acts on its documented transmission instructions. Huddleboard remains responsible for its own access, transmission and storage. Where Huddleboard engages a provider as a subprocessor, including a customer-nominated provider where that is the actual arrangement, the following subprocessor requirements apply in full. BYOK does not waive them.
The Customer gives general written authorization only for Huddleboard subprocessors identified in the service-provider inventory in Annex C. Huddleboard shall impose equivalent applicable data-protection obligations by binding agreement and remains fully liable to the Customer for its subprocessors' performance of those obligations. It shall provide their identity, function and location and notify the Customer's privacy contact at least 30 days before additions or replacements.
The Customer may object during that period on reasonable data-protection grounds. The parties shall seek an alternative; if unresolved, the affected processing shall not start with the disputed provider and the Customer may terminate the affected service without penalty. A model catalogue update is not blanket authorization for an undisclosed processing chain. Neither a free price nor the Customer's choice of a model overrides these requirements.
5. International transfers
Huddleboard shall make restricted transfers only on documented instructions and with a valid GDPR Chapter V mechanism. The service-provider inventory shall record relevant destinations, recipients and the applicable adequacy decision or safeguards, such as the appropriate executed Standard Contractual Clauses, transfer assessment and supplementary measures where needed. EU hosting, an API key and general acceptance of this agreement are not transfer safeguards. A route without established coverage must not process Customer Personal Data. This agreement does not itself execute transfer SCCs.
6. Rights requests and assistance
Taking account of the nature of processing, Huddleboard shall assist the Customer with access, rectification, erasure, restriction, portability and other applicable data-subject rights through appropriate technical and organizational measures. It shall forward requests concerning Customer Personal Data without undue delay and not answer on the Customer's behalf unless instructed or legally required. Requests about Huddleboard's own controller processing are handled separately.
Huddleboard shall provide information and reasonable assistance necessary for the Customer's security obligations, DPIAs and prior consultation, taking into account available information. The Customer remains responsible for its decisions and statutory deadlines. The parties may agree reasonable charges for exceptional assistance in advance; charges shall not obstruct statutory assistance or remedying Huddleboard's own breach.
7. Personal data breaches
Huddleboard shall notify the Customer's privacy contact without undue delay after becoming aware of a personal data breach affecting Customer Personal Data. It shall not wait for a complete investigation. Information shall include, as available, the nature of the breach, affected data and individuals, approximate volumes, likely consequences, mitigation and contact details. Missing information shall follow in stages without undue delay. Huddleboard shall contain, investigate, document and remediate the breach and assist with required notifications. This does not transfer the Customer's regulatory notification responsibility to Huddleboard.
8. Return, erasure and retention
At the end of services, the Customer chooses return or deletion of Customer Personal Data. Where return is chosen, Huddleboard shall provide an agreed usable export and then delete remaining copies, unless Union or Member State law requires retention. Export exclusions shall be disclosed and any Customer Personal Data needed to satisfy the request supplied securely by an appropriate method.
Primary workspace data shall be erased within 30 days of a verified deletion instruction or service termination, subject to legally required retention. Backup copies shall expire within 35 days after primary erasure, at most 65 days after the triggering event. During that interval they shall be isolated from ordinary use; an erasure ledger shall be applied before restored data is made available. Legally retained data shall be limited to the required purpose and period. On request Huddleboard shall confirm completion and explain any lawful retention.
Deleting one user account does not erase shared workspace content. The Customer may separately instruct removal or redaction of personal information in that content. Revoking a key does not delete prior data at a connected provider. Huddleboard shall assist with downstream erasure within its role and contractual control; direct-provider requests are coordinated with the Customer.
9. Accountability and audit
Huddleboard shall maintain required processing records and make available information necessary to demonstrate compliance. It shall allow and contribute to audits, including inspections, by the Customer or its mandated independent auditor. Reasonable notice, confidentiality and proportionate scope may protect other customers and system security, but shall not prevent legally required, incident-related or supervisory-authority audits. Existing evidence may satisfy a request only where sufficient. No certification or independent audit is represented by this agreement.
10. Duration, precedence and law
This agreement continues while Huddleboard retains Customer Personal Data, including protected backup retention. It prevails over conflicting service terms for that processing; mandatory law and applicable transfer SCCs prevail over it. Amendments require written agreement, except for authorized subprocessor notices under section 4. Nothing limits data subjects' or authorities' rights or mandatory GDPR liability. Polish law applies without displacing mandatory protections.
Annex A — Processing description
- Subject and purpose: collaborative software planning and delivery using boards, tickets, comments, attachments, repository integration, AI assistance and optional voice huddles. - Duration and frequency: ongoing during covered workspace use, followed by section 8 retention. - Individuals: Customer personnel, contractors, collaborators and other people whose information the Customer lawfully includes in permitted workspace content. - Data: names, professional contact details, user identifiers, authorship and activity, ticket and comment content, attachments, source/review context, generated outputs and run traces. If voice is expressly enabled, conversation audio/context and retained transcripts are included. Voice is not authorized for biometric identification. Only data needed for the selected operation is transmitted. - Scope: the acceptance record identifies the workspace; enabled connections follow its configuration.
Annex B — Agreed security measures
Huddleboard shall maintain authenticated access and workspace authorization; restricted administrative access; encrypted transport for production connections; encrypted provider-key storage with a separately managed encryption secret; and private, encrypted production storage and backups. Authorized runtimes may decrypt a provider key in memory to make requests. This is not end-to-end encryption against the service operator.
Measures also include scoped agent permissions, bounded runs, reviewable activity, controlled software changes, incident handling and security logging without intentional capture of keys, raw login codes or workspace content. Security logs shall be retained no longer than 30 days. Expired login proofs shall be removed within 24 hours after expiry. Access shall be revoked when no longer required. Restore and erasure procedures shall be tested before production activation and after material changes. Evidence shall be made available under section 9.
Annex C — Service-provider inventory
AWS supplies configured hosting, storage, database, logs and email; the configured hosting region is Frankfurt. Cloudflare supplies DNS; DNS-only use does not expose workspace HTTP content. GitHub supplies customer-connected repositories. OpenRouter and the selected model-processing chain supply task inference through the customer's account. OpenAI supplies optional voice through a customer-connected account where that arrangement is permitted. Optional Google sign-in is described separately in the privacy notice; its availability alone does not make Google a subprocessor for workspace content.
Huddleboard shall maintain and make available the exact recipient identities, processing roles, locations and safeguards for the services it engages. It shall satisfy sections 4 and 5 before processing Customer Personal Data with a recipient. The inventory is not a representation of EU-only processing, provider certification or blanket approval of every catalogue model. Customer-connected services remain subject to section 4 and their applicable provider agreements.
This standard inventory does not require the Customer to negotiate or sign a separate schedule. It also does not excuse Huddleboard from verifying its own subprocessor contracts and transfer arrangements. Changes follow section 4, including advance notice and the right to object.
The Polish and English versions form one document; this does not change the precedence of mandatory law and applicable SCCs.