Data Processing.

Agreement on data processing pursuant to Art. 28 of Regulation (EU) 2016/679 (GDPR) for the Eigenwelt Plus service.

This is the current version published at eigenweltlabs.com/de/eigenwelt-plus/avv (§ 12). The German version is legally binding; the English translation is provided for convenience only. The version signed by both parties is the agreed basis.

Parties

between

[Name of the firm / company]
[Represented by]
[Street, number]
[Postcode, city]
– hereinafter the “Controller” –

and

Eigenwelt Labs UG (haftungsbeschränkt)
c/o Bridgemaker GmbH, Linienstraße 86, 10119 Berlin
Local court Berlin (Charlottenburg), HRB 292971 B
represented by its managing directors Johann Frederik Machemer and Christian-Hauke Poensgen, each authorised to represent the company individually
– hereinafter “Eigenwelt” or the “Processor” –

§ 1 Subject matter and term

(1) The Controller uses the “Eigenwelt Plus” service (hosted model inference, team and organisation administration, Knowledge Hub, intake and tasks, and managed connector sign-in, available at platform.eigenweltlabs.com) on the basis of the Terms and Conditions for Eigenwelt Plus (the “Main Agreement”). In providing the service, Eigenwelt processes personal data on behalf of and on the instructions of the Controller. This agreement sets out the parties’ data-protection obligations in detail.

(2) The subject matter, nature, and purpose of the processing, the type of personal data, and the categories of data subjects are set out in Annex 1.

(3) The term of this agreement corresponds to the term of the Main Agreement. It ends automatically upon the latter’s termination; surviving obligations (in particular §§ 11 and 13) remain unaffected.

§ 2 Zero data retention for inference content

(1) Eigenwelt’s gateway does not store any prompt or output content of paid inference and retains only content-free billing and usage metadata (in particular user, model, token count, cost, status, and timestamp).

(2) Zero data retention (“ZDR”) is enabled for Eigenwelt’s accounts with the inference subprocessors (Annex 3). Under the published terms of TensorX Limited, prompts and outputs are processed only transiently in ephemeral enclaves and are persisted to no storage system; Fireworks.ai, Inc. does not log or store prompt and generation data absent an explicit opt-in. Under the published policy of Scaleway SAS, temporary access and retention for up to two weeks are permitted only to investigate abnormal errors or suspected malicious activity; aggregated, anonymised usage data may be retained for up to six months.

(3) For the Gemini models served through Google Cloud (Vertex AI), Google has switched off abuse-monitoring logging for Eigenwelt. Prompts are therefore not logged or retained there for abuse monitoring either; ZDR under paragraph 2 applies to these models without qualification.

(4) Paid inference content is not used to train shared or public models.

(5) ZDR does not apply to account, billing, security, and usage data, to Knowledge Hub content and tasks that the Controller deliberately stores in the platform, to messages received through intake, or to OAuth credentials, connection metadata, or authentication logs of managed connections.

(6) Zero data retention is enabled on Eigenwelt’s TypeSafe account for the “Eigenwelt US Jev” model. TypeSafe AI, Inc. processes submitted inference content under this ZDR configuration. The model is used only where an administrator has enabled both the United States hosting region and this model.

(7) Eigenwelt obtains the Claude models (Anthropic) and the GPT models (OpenAI) through OpenRouter, Inc.; direct access through Amazon Bedrock under paragraph 9 is also provided for the Claude models. When using OpenRouter, Eigenwelt technically enforces a regional host, an allowlist of approved model endpoints, and zero data retention for every request; access keys are restricted to the respective region. For EU models, the approved model endpoints must be within the European Union. OpenRouter’s broader “Europe” region, which also includes non-EU countries, is insufficient on its own. An endpoint’s zero-data-retention status rests on the policy its provider has published or represented to OpenRouter. According to OpenRouter’s published information, a request sent through a regional host is decrypted only in that region and routed only to endpoints in that region. Requests are processed on the infrastructure of the cloud providers named in Annex 3 and are not sent to Anthropic’s or OpenAI’s own interfaces. Under OpenRouter’s data processing agreement, inputs and outputs are deleted promptly after the output is generated, except where retention is required by law or necessary to address malicious use; automated risk classification before deletion does not result in the content being stored. Content-free request metadata is stored (in particular timestamps, model, and token counts); OpenRouter also processes it in the United States (§ 9(3)). OpenRouter’s data processing agreement incorporates Module 2 of the EU Standard Contractual Clauses for transfers to third countries.

(8) Mistral Large 4 (Eigenwelt Europe Mistral) is obtained directly from Mistral AI. Organisation-level ZDR is enabled for Eigenwelt's stateless chat requests; inputs and outputs are not stored or logged after the output is generated. Use of API data for training is separately disabled.

(9) For the Claude models, Eigenwelt may use Amazon Bedrock directly through Amazon Web Services EMEA SARL under the AWS data processing agreement. EU and US inference use separate regional Bedrock inference profiles within the same AWS account; the enabled hosting region determines the inference route. EU requests enter in Ireland and are processed exclusively through approved EU inference profiles within Ireland, France, Germany, Sweden, Italy, and Spain. For the US Claude models, requests enter in Northern Virginia and are processed exclusively within Northern Virginia, Ohio, and Oregon; an administrator must have enabled both the United States hosting region and the respective model. AWS retention is set to “none” in both entry regions, and logging of prompt and output content is disabled. Models requiring routine content retention are not used through this route. On technical failure or capacity shortage, OpenRouter under paragraph 7 may serve as a fallback to the same model version. The Controller's model permissions, selected hosting region, ZDR, and displayed model prices also apply to the fallback. Switching to an unauthorised region, an unauthorised model, or an endpoint requiring routine content retention is excluded; if no suitable route is available, the request fails.

For Bedrock, AWS’s abuse-detection policy applies. AWS may retain and review image inputs or outputs flagged as suspected child sexual abuse material (CSAM) solely to determine whether they are CSAM, and may report to NCMEC (United States) or a relevant authority. The policy specifies no fixed retention period for this review. Details are in the AWS abuse-detection policy.

§ 3 Instructions

(1) Eigenwelt processes personal data only on the documented instructions of the Controller, unless processing is required by Union or Member State law; in such a case, Eigenwelt informs the Controller of that legal requirement before processing, unless the law in question prohibits such notification.

(2) Instructions are initially the Main Agreement, this agreement, and the use of the platform’s features by the Controller and its users. Supplementary instructions require text form.

(3) Eigenwelt informs the Controller without undue delay if it considers that an instruction infringes the GDPR or other data-protection provisions (Art. 28(3) subpara. 2 GDPR). Eigenwelt is entitled to suspend performance of the instruction concerned until it is confirmed.

§ 4 Confidentiality

(1) Eigenwelt ensures that persons authorised to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality (Art. 28(3)(b) GDPR). The confidentiality obligations continue after the activity ends.

(2) Any confidentiality agreement concluded between the parties under § 43e BRAO and § 203 StGB remains unaffected and applies alongside this agreement.

§ 5 Technical and organisational measures

(1) Eigenwelt implements the technical and organisational measures described in Annex 2 pursuant to Art. 32 GDPR and maintains them for the term.

(2) The measures may be adapted to technical and organisational developments, provided that the agreed level of protection is not reduced. Material changes are documented.

§ 6 Subprocessors

(1) The Controller authorises the subprocessors listed in Annex 3 (general written authorisation within the meaning of Art. 28(2) GDPR).

(2) Eigenwelt informs the Controller in good time before the intended addition or replacement of a subprocessor, in text form (e.g. by email or via the platform). The Controller may object to the change on important data-protection grounds. If no mutual solution is reached, the Controller may terminate the Main Agreement extraordinarily with effect from the time of the change.

(3) By contract, Eigenwelt imposes on each subprocessor the same data-protection obligations set out in this agreement, in particular sufficient guarantees of appropriate technical and organisational measures. Where a subprocessor fails to meet its obligations, Eigenwelt remains liable to the Controller for the performance of that subprocessor’s obligations (Art. 28(4) GDPR).

(4) Paid inference content is transmitted to model infrastructure within the European Union unless a further hosting region has been enabled under § 9(2). For Mistral, the processing locations under § 9(4) apply.

§ 7 Assistance to the Controller; data-subject rights

(1) Eigenwelt assists the Controller, by appropriate technical and organisational measures, in responding to data-subject requests under Chapter III GDPR. Requests from data subjects received by Eigenwelt that evidently concern the Controller are forwarded to the Controller without undue delay.

(2) Taking into account the nature of the processing and the information available to it, Eigenwelt assists the Controller in complying with the obligations under Art. 32 to 36 GDPR (security of processing, breach notification, data-protection impact assessment, prior consultation).

§ 8 Notification of personal-data breaches

(1) Eigenwelt notifies the Controller of any personal-data breach affecting data processed on its behalf without undue delay after becoming aware of it.

(2) The notification contains, where available, the information required under Art. 33(3) GDPR; information not immediately available is supplied without undue further delay.

§ 9 Place of processing; transfers to third countries

(1) Core platform data is processed in the European Union (Annex 3). For paid inference content, the European Union is the default: unless the Controller has enabled a further hosting region under paragraph 2, inference content is transmitted to model infrastructure within the European Union. For Mistral, the processing locations under paragraph 4 apply. A model newly added by Eigenwelt remains deactivated until an administrator of the Controller activates it.

(2) An administrator of the Controller may enable further hosting regions in the platform (currently the United States). That selection constitutes the Controller’s prior documented instruction within the meaning of Art. 28(3)(a) GDPR to transmit paid inference content to model infrastructure in the selected region, and is logged by Eigenwelt. It may be withdrawn at any time with effect for the future.

(3) Any transfer of personal data to a third country — as part of processing under paragraph 2, 4, or 5, because of a subprocessor’s place of establishment, or as a result of limited support access in an individual case — takes place only on the basis of an adequacy decision or appropriate safeguards within the meaning of Chapter V GDPR (in particular EU Standard Contractual Clauses). Otherwise, no transfer of personal data to third countries takes place, and none is carried out without the Controller’s prior documented instruction.

(4) For Mistral Large 4, Eigenwelt uses Mistral AI's EU regional endpoint. Its processing locations are described in the Eigenwelt Plus Privacy Notice. The model is used when an administrator has enabled it. Account, billing, and operational metadata may be processed outside the inference region; where personal data is processed on behalf of the Controller, paragraph 3 applies.

(5) Where an authorised user of the Controller uses managed sign-in for a supported Google or Microsoft account, Nango Inc. processes OAuth credentials and connection, permission, and profile metadata in the United States (Annex 3). This optional use is an instruction under § 3(2) for authentication and token management for that connection; enabling a model region under paragraph 2 does not govern it. § 6 and the requirements of paragraph 3 remain unaffected. Email, calendar, file, and attachment content is not routed through Nango or the platform authentication endpoint for these connectors.

§ 10 Evidence and audits

(1) Eigenwelt makes available to the Controller all information necessary to demonstrate compliance with the obligations under Art. 28 GDPR. This is provided primarily through documentation, in particular the documentation of technical and organisational measures (Annex 2), existing certificates and attestations (in particular ISO/IEC 27001 and BSI C5), and audit reports of the subprocessors used, supplemented by responses to a reasonable written questionnaire no more than once per calendar year.

(2) The Controller may request an on-site review (inspection) only where (a) the evidence provided under paragraph 1 is demonstrably insufficient to establish compliance in the individual case, (b) a competent supervisory authority bindingly orders this in respect of the Controller, or (c) there is a documented personal-data breach affecting the Controller’s data.

(3) Inspections are limited to at most one per calendar year (except in the cases of paragraph 2(b) and (c)), to be announced at least 30 days in advance in text form, limited to ordinary business hours, and carried out without disrupting operations and while preserving the confidentiality and rights of other customers. Any auditor engaged must be independent and bound to secrecy and must not be a competitor of Eigenwelt; Eigenwelt may reject an auditor for good cause. The Controller bears the cost of the inspection, including Eigenwelt’s reasonable effort.

§ 11 Deletion and return

(1) Prompt and output content of paid inference is governed by § 2, including the provider-specific exceptions described there. Eigenwelt’s gateway does not store that content, so no separate deletion at the gateway is required in that respect.

(2) After termination of the Main Agreement, Eigenwelt deletes or anonymises the remaining personal data processed on the Controller’s behalf within a reasonable operational period or, at the Controller’s request, returns it in a common format where technically possible. The Controller exports needed Knowledge Hub content before the contract ends; Eigenwelt assists to a reasonable extent.

(3) Statutory retention obligations and data in backups with defined deletion cycles remain unaffected; the protection obligations of this agreement continue to apply to such data.

(4) After a successful disconnect of a managed connection, Eigenwelt arranges its deletion at Nango. This stops further token delivery through that connection; it is separate from revoking authorization at the Google or Microsoft account. Deactivation or sign-out alone does not delete the managed connection. Remaining connection records are also covered by deletion and return instructions under paragraph 2; paragraph 3 applies to necessary security logs and backups. Disconnecting does not delete original content at the connected provider or local working copies.

§ 12 Updates and versioning

(1) This agreement bears a version number and a date. The current version is published at eigenweltlabs.com/de/eigenwelt-plus/avv. The version signed by both parties is the agreed basis; updates take effect in accordance with this section.

(2) Changes to the technical and organisational measures (Annex 2) are governed by § 5(2) and must not fall below the agreed level of protection. Changes to the subprocessors (Annex 3) are governed by § 6. Such updates to the annexes take effect without renewed signature; the Controller’s rights under § 6(2) (objection and extraordinary termination) remain unaffected.

(3) Eigenwelt notifies the Controller of changes to the main body of this agreement at least 30 days before they take effect, in text form (e.g. by email or via the platform). If the Controller does not object within 30 days of receipt, the new version is deemed accepted. Material changes disadvantaging the Controller require its consent in text form. If no agreement is reached, the most recently agreed version continues to apply; the right to terminate the Main Agreement remains unaffected.

(4) Changes required by mandatory legal provisions, by an order or recommendation of a supervisory authority, or by a change in the case law of the highest courts, Eigenwelt may implement with effect from the required time; Eigenwelt informs the Controller of this without undue delay.

(5) Either party may at any time request a copy of the current version countersigned by both parties. Eigenwelt keeps a traceable record of the versions of this agreement (change history).

§ 13 Liability and final provisions

(1) The parties’ liability is governed by the provisions of the Main Agreement and by Art. 82 GDPR.

(2) In the event of conflict between this agreement and the Main Agreement, this agreement prevails on data-protection matters.

(3) Supplementary amendments and side agreements require text form; § 12 remains unaffected. German law applies; the exclusive place of jurisdiction, to the extent legally permissible, is Berlin.

(4) Should individual provisions of this agreement be invalid, the validity of the remaining provisions remains unaffected; the invalid provision is replaced by a provision that comes closest to the purpose of Art. 28 GDPR.

Place, date — For the Controller — [Name in block letters]
Place, date — For Eigenwelt Labs UG (haftungsbeschränkt) — Managing director, [Name in block letters]

Annex 1 – Subject matter of the processing

1. Processing operations

• Hosted model inference: processing of prompts, inputs, documents or document excerpts, and generated output to provide the AI features. Processing takes place transiently in memory; content is not stored, in accordance with § 2 of the agreement (zero data retention).
• Knowledge Hub: storage and provision of content that the Controller deliberately stores (e.g. workflows, integrations, plugins, MCP server definitions, presets, permissions, version history).
• Intake and tasks: receipt of emails sent to the Controller’s intake addresses and of submissions through the intake API, once an administrator has activated intake; checking the sender against the Controller’s rules; creation and assignment of tasks with an AI model through the paid gateway (§ 2(1) to (4)); storage of messages, attachments, and tasks, and their synchronisation with LegalWork.
• Team and organisation administration: management of members, roles, invitations, and organisation-wide settings.
• Content-free usage and billing metadata: user, model, token count, cost, status, timestamp.
• Managed connector sign-in: setup, validation, refresh, and disconnection of OAuth connections bound to a user and firm; credential storage at Nango and delivery of short-lived access tokens by the platform to the LegalWork server. Processing serves the account explicitly connected; email, calendar, file, and attachment content is not transmitted through Nango or the platform authentication endpoint in this process.

2. Purpose of the processing

Provision, security, billing, and support of the Eigenwelt Plus service in accordance with the Main Agreement.

3. Type of personal data

• All personal data contained in content submitted by the Controller or its users, in particular master data, contact data, contract, case, and matter data, and communication content.
• This may include special categories of personal data (Art. 9 GDPR) and data relating to criminal convictions and offences (Art. 10 GDPR), where these are the subject of the content processed by the Controller.
• Platform user data: name, email address, organisation membership, role.
• Managed sign-in connection data: OAuth access and refresh tokens, connection and provider identifiers, user and organisation ownership, account and profile metadata, permissions, status, timestamps, and technical authentication and security data. The content categories described above are not sent to Nango as part of this authentication feature.

4. Categories of data subjects

• the Controller’s clients and their staff or officers,
• opposing parties, participants in proceedings, and other third parties whose data is contained in processed content,
• the Controller’s staff and users.

Annex 2 – Technical and organisational measures (Art. 32 GDPR)

As of 16 October 2026. The measures are continuously adapted to the state of the art; the level of protection is not reduced in doing so.

1. Location and physical-access control

• Platform, gateway, and databases run exclusively in data centres within the European Union: Google Cloud region europe-west3 (Frankfurt am Main). Eigenwelt Europe EigenJev is operated by Eigenwelt on Google Cloud in region europe-west4 (Netherlands). For the Google Cloud services used (including Cloud Run, Cloud SQL, Cloud Storage, Memorystore), storage of data at rest is restricted to the selected region. Model inference takes place in the European Union (TensorX, Dublin and Helsinki; Scaleway, Paris, region fr-par; Google Cloud Vertex AI with EU data residency), unless a further hosting region has been enabled under § 9(2); for Mistral, the processing locations under § 9(4) apply.
• Certifications of the providers used: Google Cloud is certified to ISO/IEC 27001:2022 and holds a BSI C5:2020 attestation. Scaleway S.A.S. is certified to ISO/IEC 27001:2022 (BSI, certificate IS 787020, for the technical infrastructure platform of the public-cloud products). OpenRouter, Inc. holds a SOC 2 Type 2 report. The certification status of the remaining subprocessors is assessed before they are engaged and monitored on an ongoing basis. No physical access by Eigenwelt personnel.
• Optional managed connector sign-in uses Nango Cloud in the United States for credentials and connection metadata (§ 9(5)). It is separate from EU hosting of Eigenwelt’s own platform and from model regions.

2. Access and authorisation control

• Role-based access concepts following the least-privilege principle; personalised accounts, multi-factor authentication for administrative access.
• Authentication of API use via organisation-specific keys or token-based sign-in; authorisation checks at organisation level.
• Management of secrets (credentials, keys) in dedicated secret management.

3. Transmission and disclosure control

• Transport encryption of all connections (TLS); encryption of stored platform data to provider standard (encryption at rest). The gateway access keys issued per user and organisation are additionally stored encrypted at the application layer using AES-256-GCM, with the corresponding keys held in the infrastructure provider’s secret manager.
• Technical prevention of logging of inference content at the gateway: content is redacted from logs and downstream systems; client-side disabling of this redaction is technically excluded.
• Managed connections are checked for user and firm ownership for status, reconnect, token retrieval, and deletion. Nango runtime keys are separately restricted for metadata and credentials; proxy, sync, action, and account-enumeration permissions are not used. The platform returns only the access token needed; tokens are not exposed in tool results or logs.

4. Separation and input control

• Logical tenant separation at organisation level; separate environments for the paid service (zero data retention) and the separate evaluation gateway for free models.
• Traceability of administrative operations and security-relevant events through content-free logs.

5. Data minimisation and zero data retention

• No storage of prompt and output content of paid inference; retention of content-free billing metadata only.
• Automated checks (including continuous tests) that the zero-data-retention configuration is effective.

6. Availability and resilience control

• Managed, redundant database and infrastructure services; regular backups of platform data with defined deletion cycles; monitoring and alerting.

7. Commissioned-processing control and organisation

• Data-processing agreements with all subprocessors; selection by suitability and certification status; regular review.
• Internal process for security incidents (detection, assessment, notification, follow-up); regular review and evaluation of the effectiveness of the measures (Art. 32(1)(d) GDPR).

Annex 3 – Authorised subprocessors

As of 19 October 2026. Changes to this list are governed by § 6 (advance notice, right of objection and extraordinary termination) and § 12.

Note 1: Paid inference content is transmitted to model infrastructure within the European Union, unless a further hosting region has been enabled under § 9(2); for Mistral, the processing locations under § 9(4) apply. An inference subprocessor on this list acts for the Controller only once an administrator has activated a model of that provider. Nango acts for a connection explicitly authorised by the user under § 9(5); § 6 remains unaffected. Where processing takes place in a third country — because of the model or region selection, managed connector sign-in, a provider’s place of establishment, or limited support access in an individual case — it is contractually limited to what is necessary and safeguarded by the guarantees set out in § 9 (in particular EU Standard Contractual Clauses under Chapter V GDPR).

Note 2: Payment processing for fees is carried out by a payment service provider in relation to Eigenwelt as the data controller and is not the subject of this commissioned processing. Details are set out in the Eigenwelt Plus Privacy Notice.

Note 3: The platform’s product analytics is carried out in relation to Eigenwelt as the data controller and is not the subject of this commissioned processing. It is limited to explicitly named events, relates to the organisation rather than to individuals, and captures no prompt or output content; the paid inference gateway is excluded from it. Details are set out in the Eigenwelt Plus Privacy Notice.

Questions about data processing, or to request a countersigned copy: chris@eigenweltlabs.com.