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Data Processing Agreement - supplemental agreement covering AI Features of MyClients365

Version: 1.0.1 | Effective Date: Aug 18 2025

Introduction

This Data Processing Agreement ("DPA") supplements the MyClients365 (“MYC365”) Terms of Use and Privacy Policy. It governs the processing of personal data in connection with the use of AI-powered features in MYC365.
By using AI Features, you "User", agree to the terms of this DPA.

1. Definitions

• MYC365: Refers to the MyClients365 application developed by Ultimate Web Apps Ltd (“UWA”), a company incorporated in Ireland, with its registered office at Carriglea, Killenard, Co. Laois, Ireland.
• AI Features: Features within MYC365 powered by artificial intelligence including but not limited to:
  • email/document summarisation
  • content generation
  • writing assistance
  • text analysis and recommendations
• User or You: Refers to any individual or legal entity accessing or using the AI Features within MYC365.
• Personal Data: Any information that identifies or can reasonably be linked to an individual.

2. Data Collection and Processing

When you use AI Features in MYC365, the following types of data may be processed:

• Content submitted for AI analysis (e.g. emails, case entries, documents)
• AI-generated outputs (summaries, suggestions, rewritten content)
• User interaction and usage logs (feature usage metadata, timestamps, IP address)
• Technical metadata (browser, device type, user ID, session ID)

3. Purpose of Processing

Data is processed for the following purposes:

• To provide AI-powered features as part of the MYC365 application
• To deliver contextual suggestions, summaries and content transformations
• To monitor system performance and ensure feature reliability
• To troubleshoot issues and support customer requests
• To comply with applicable legal and regulatory requirements

4. Data Sharing and Subprocessors

Your data may be shared with:

• Third-party AI service providers (e.g., OpenAI, Azure OpenAI) solely for real-time processing with contractual safeguards in place
• Cloud infrastructure providers (e.g., Microsoft Azure) for secure hosting and processing
• Internal MYC365 support teams, only when necessary for technical assistance

Important:

• Your data is not sold to third parties under any circumstances.
• Your data is not shared for advertising or marketing purposes under any circumstances.
• All Subprocessors are required to comply with GDPR, CCPA, and other relevant regulations.

5. Data Retention

• AI-generated content: Retained as part of your account data for as long as your account remains active, unless manually deleted.
• Processing logs: Retained for diagnostic and debugging purposes for as long as your account remains active, unless manually deleted.
• Anonymized analytics: Aggregated and stored indefinitely to improve system performance and UX.

6. Your Rights

As a data subject under GDPR and other applicable laws, you have the right to:

• Access a copy of your data processed by AI features
• Request deletion of specific AI-generated content
• Withdraw consent, which will disable access to AI functionalities
• Export or request a copy of your generated content (data portability)
• File a complaint with a supervisory authority regarding data misuse

7. Security Measures

The following safeguards are employed to protect your data:

• End-to-end encryption for data in transit
• Encryption at rest for data
• Secure backup procedures
• Secure APIs and authentication layers
• Access controls and permission-based roles
• Hosting in GDPR-compliant cloud environments within the European Economic Area (EEA), including Ireland

8. Disclaimer and Limitations

AI-generated content is provided for informational purposes only. UWA does not guarantee the accuracy, completeness, or legal validity of AI outputs. Verification, validation or use of any AI-generated output is at your sole discretion. UWA shall not be liable for any acts, omissions or decisions made based on AI content or outputs.

9. AI Model Training

Unless explicitly stated otherwise, your data is not used to train or fine-tune underlying AI models. All processing is conducted in real time and is stateless (no memory is retained across sessions unless saved by you in MYC365).

10. Changes to this DPA

This DPA may be updated periodically to reflect new legal requirements or changes to AI processing practices. When updated, you will be notified by email or in-app notifications. Continued use of AI Features after changes constitutes your acceptance of the revised DPA.

11. Contact Information

For any questions or concerns regarding this DPA or AI-related data use, please contact:

Email: info@myclients365.com
Postal Address:
Ultimate Web Apps Ltd
Carriglea, Killenard, Co. Laois
Ireland