Data Processing Addendum

This Data Processing Addendum ("DPA") forms part of the Terms or other agreement between the customer ("Controller") and BLINKHOST LTD ("Processor") where BlinkHost processes personal data in customer content on the Controller's behalf.

1. Instructions and compliance

Processor will process customer personal data only to provide and secure the service, on documented Controller instructions, or as required by law. Where law requires other processing, Processor will notify Controller unless prohibited. Each party will comply with the Nigeria Data Protection Act 2023 and other law applicable to its role. Controller is responsible for lawful instructions, notices, legal bases and responding to data subjects.

2. Processing details

Subject and purpose: authorised source collaboration, browser and isolated backend preview execution, build, hosting, deployment, project-asset storage and security scanning, edge delivery, managed database, application observability and support. Duration: service term plus disclosed export, retention and deletion periods. Nature: collection, validation, security scanning, execution, storage, organisation, retrieval, transmission, replication, aggregation, backup, export and deletion. Data: customer-selected application/database content, identifiers, contact, usage, device, communications, logs, traces, metrics and runtime decisions. Subjects: Controller's users, personnel, customers, application visitors and others whose data Controller submits.

3. Confidentiality and security

Authorised personnel are bound by confidentiality. Processor maintains measures appropriate to risk, including tenant-scoped access, encryption, identity and secret controls, logging, release controls, monitoring, backups and incident response. Controller remains responsible for its application security, user access, secrets and configuration.

4. Service providers

Controller authorises Processor to use service providers for infrastructure, storage, networking, email, managed databases, payments, source collaboration, security and support. Processor requires providers that process customer personal data to protect it under written data-protection obligations appropriate to the service and remains responsible as required by law. We will give reasonable advance notice by email or through the service before appointing a materially different provider that processes customer personal data. Controller may object on documented data-protection grounds; the parties will seek a reasonable alternative, and Controller may discontinue the affected service if none is available.

5. Assistance and incidents

Taking account of the processing and information available, Processor will reasonably assist with data-subject requests, security, breach assessment/notification, impact assessments, regulator consultation and compliance evidence. Processor will notify Controller without undue delay after confirming a breach affecting customer content and provide available material information as investigation progresses.

6. International transfers

Processor will use an applicable lawful transfer basis, appropriate contractual safeguards and supplementary technical/organisational measures for restricted international transfers.

7. Return, deletion and audit

On termination and request, Processor will provide reasonable tenant-scoped export and delete or return data unless law requires retention. Protected recovery copies require separate retention and deletion handling. Processor will explain applicable retained categories and limitations when responding to a return or deletion request; a separately created restore copy does not automatically expire with the source backup. A documented, time-bounded legal hold may preserve a narrow scope. Processor will provide information reasonably necessary to demonstrate compliance and support proportionate audits, subject to confidentiality, security, reasonable notice and avoidance of disruption.

8. Precedence and contact

This DPA controls a conflict about processor activity. Liability follows the main agreement subject to non-excludable rights. Contact privacy@blinkhost.me.

Source collaboration instructions

Controller authorizes Processor to process connected source and participating-user data only as needed to perform the source import, synchronization, collaboration, template installation, review, handoff and evidence functions selected by Controller's authorized users. Controller is responsible for invitation authority, role selection, notice to invited users, lawful instructions and removal of access that is no longer required.

Recoverable collaboration content follows the contracted plan retention. Reviews, approvals and security evidence may be retained for security, dispute and compliance periods stated in the Privacy Policy or applicable retention schedule. Evidence export objects expire after seven days unless law requires preservation. These periods do not require Controller to retain a downloaded copy.

Live co-editing instructions

Controller instructs Processor to synchronize source changes and process participant identity, access, presence and recovery data when Controller's authorized users enable or use live co-editing. Controller is responsible for the lawful basis and notices applicable to invited users, the source placed in the service, role and file-scope decisions, endpoint security and timely access revocation.

Recoverable edit history follows the contracted plan retention, subject to documented legal holds and the deletion and security provisions of this Addendum. Short-lived presence is used only to provide and protect the active collaboration experience.

Hosted Object Storage

Where Hosted Object Storage contains Personal Data submitted through a customer application, that data is Customer Data processed under this Addendum. Processing may include receipt, security scanning, validation, storage, retrieval, delivery, backup and deletion. The Customer remains responsible for configuring public or private access and for giving end users the notices and choices required for the Customer's processing.

Asynchronous function processing

Where function payloads or results contain Personal Data, they are Customer Data processed to queue, execute, retry, observe, secure, retrieve, and delete the requested work. Processing may occur after the initiating browser or HTTP session ends. BlinkHost applies tenant scoping, integrity verification, access control, bounded retention, and deletion to stored invocation data.

Release compatibility processing

On the Controller's behalf, BlinkHost may compare declared component versions and bounded build, deployment or authenticated CLI-session evidence with published compatibility rules. Results identify the component, detected version, evidence source, confidence and required action. This process does not authorise unrelated source inspection or use of Customer Data for advertising. Access, retention, deletion, subprocessors, transfer safeguards and audit controls in this Addendum also apply to these compatibility records.

Idam AI processing instructions

Where the Controller's authorised users choose Idam, the Controller instructs BlinkHost to process the requests, selected and authorised source files, task-specific project information, saved project guidance, relevant conversation or workflow context, generated proposals and authorised tool results needed to provide the requested AI assistance. Processing includes preparation and transmission of model input, receipt and storage of output, task coordination, history, export, security and usage accounting. The subjects and personal-data categories depend on the content the Controller supplies. The Controller remains responsible for lawful instructions, access decisions and notices to the people whose data it submits.

This instruction includes device files that authorised users attach for context and recordings they submit for voice transcription. BlinkHost prepares supported text, images and selected video frames, and sends recordings to Azure OpenAI for transcription. Original files and recordings are discarded after processing. Unsubmitted prepared context and transcripts expire after 24 hours; submitted context follows task retention. Users can review and edit a transcript before submitting it as a request.

The instruction also covers public internet research, authorised connections to external services, shared preview interaction and application checks requested by authorised users. Research sends public queries without private project context. A connected external service receives the arguments needed for an authorised tool operation and may return content used in the task. The Controller determines which external services and permissions to authorise and remains responsible for its relationship with those services. Revocation does not undo completed actions or recall previously transferred data. Private sign-in remains in the user's own browser, and stored connection credentials are encrypted.

Public search uses Bing through Azure Foundry. Microsoft's processing of Bing search queries, service metadata and results is governed by the Microsoft Privacy Statement, separately from its Azure OpenAI processing terms. Microsoft acts as an independent controller, not BlinkHost's processor, for Bing search data. Private project context is excluded from these queries. Saved grounded answers and references within BlinkHost remain subject to the applicable task retention and access controls.

BlinkHost processes bounded task and service metadata for operational analytics, including performance, reliability, capability use and usage accounting. Default analytics exclude raw prompts, source code, attachments, credentials and private sign-in content. Shared preview sessions may process application captures, controls and annotations to show and verify the requested application. Access, retention and deletion of these records follow their applicable task, session, security and accounting purposes and the provisions of this Addendum.

Microsoft provides the Azure OpenAI model processing used by Idam. Microsoft's published terms for these Azure-hosted models state that prompts and responses are not available to OpenAI or other customers and are not used to train foundation models without permission or instruction. Idam does not submit Customer Data for model training. Provider abuse monitoring may include storage of flagged content and review by authorised Microsoft personnel. This Addendum does not establish a zero-data-retention arrangement for Idam.

The current model deployments are global. Model processing may occur in any supported geography for the deployment and is not confined to the resource's configured region. The service-provider, confidentiality, security, assistance and international-transfer provisions of this Addendum apply to this processing. A different residency or provider-retention requirement must be established before the affected content is submitted.

An instruction to remove content from a task or to clear saved guidance has the scope stated by that operation. It does not automatically remove other tasks or workflows containing that content, completed project changes, downloaded exports, protected recovery copies or provider records. The Controller may request broader scoped return or deletion under this Addendum. BlinkHost will distinguish content removal from the retention of restricted accounting, security, approval and execution-integrity records and explain applicable recovery-copy, provider or legal-hold limitations. Restored copies must be assessed separately; the source database's backup window is not an expiry date for a restored server.