{"id":1281,"date":"2024-11-28T11:09:45","date_gmt":"2024-11-28T11:09:45","guid":{"rendered":"https:\/\/dev.primeai.co.uk\/?page_id=1281"},"modified":"2025-11-06T08:56:32","modified_gmt":"2025-11-06T08:56:32","slug":"policies-data-processing-addendum","status":"publish","type":"page","link":"https:\/\/www.prime-ai.com\/en\/policies-data-processing-addendum\/","title":{"rendered":"Policies – Standard Data Processing Addendum (DPA)"},"content":{"rendered":"\t\t
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Policies - Standard Data Processing Agreement (DPA)<\/h1>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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Standard Data Processing Areement (DPA)<\/h6>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Last updated: 6th of November 2025<\/em><\/p>\n

This Data Processing Addendum (\u201cDPA\u201d), including its Attachments and Appendices, forms part of the Subscription Agreement or Service Agreement, Prime AI\u2019s Terms of Service available at https:\/\/www.prime-ai.com\/policies-terms-of-service\/<\/a>, or any other written or electronic agreement (the \u201cAgreement\u201d) including any service orders, purchase orders, or order forms (each a \u201cService Order\u201d) entered into between Prime AI Limited (\u201cPrime AI\u201d, \u201cProcessor\u201d) and the Subscriber (\u201cController\u201d).<\/p>\n

The purpose of this DPA is to reflect the parties\u2019 agreement regarding the processing of Subscriber Personal Data. The parties agree to comply with this DPA with respect to any Subscriber Personal Data that Prime AI processes in the course of providing the Services pursuant to the Agreement.<\/p>\n

This DPA also applies to Prime AI services delivered via third-party platforms such as the Shopify App Store, where the installation or use of a Prime AI app constitutes acceptance of Prime AI\u2019s Terms of Service and this DPA.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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1. Definitions<\/h6>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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1.1 \u201cPrime AI\u201d means Prime AI Limited, Registered in England & Wales No. 11599467, Oakwood Lodge, Thornden Wood Road, Herne Bay, CT6 7NX.<\/p>

1.2 \u201cAffiliates\u201d means entities that directly or indirectly control, are controlled by, or are under common control with a party and that are engaged in the processing of Subscriber Personal Data in connection with the subscribed Services, provided such processing is subject to applicable Data Protection Laws.<\/p>

1.3 \u201cData Incidents\u201d means a breach of Prime AI\u2019s security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Subscriber Data transmitted, stored or otherwise processed by Prime AI. \u201cData Incidents\u201d do not include unsuccessful attempts or activities that do not compromise security (such as failed log-in attempts or network scans).<\/p>

\u201cData Protection Laws\u201d means all applicable data-protection and privacy legislation governing the processing of personal data under this DPA, including without limitation:
(a) the EU General Data Protection Regulation (Regulation (EU) 2016\/679);
(b) the UK GDPR and the UK Data Protection Act 2018; and
(c) any other applicable data-protection or privacy laws in jurisdictions where Subscriber Personal Data is processed or where the Subscriber is established.<\/p>

1.4 \u201cDPA Effective Date\u201d means the date when the Subscriber accepted this DPA electronically or otherwise agreed in writing.<\/p>

1.5 \u201cEEA\u201d means the European Economic Area. \u201cRestricted Transfer\u201d means a transfer of personal data to a third country not covered by an adequacy decision under the relevant Data Protection Laws.<\/p>

1.6 \u201cSecurity Documentation\u201d means all materials made available by Prime AI to demonstrate compliance with this DPA, including the Security Measures, Additional Security Information, and any independent certifications or audit reports, as applicable.<\/p>

1.7 \u201cSecurity Measures\u201d means the technical and organisational safeguards adopted by Prime AI applicable to the Services subscribed by the Subscriber, as described in the Technical and Organisational Measures Policy available to Subscribers on request.<\/p>

1.8 \u201cSub-processor\u201d means any third party (including Prime AI\u2019s Affiliates) engaged by Prime AI to process Subscriber Data in connection with the Services. Prime AI maintains an internal record of authorised Sub-processors and ensures that each Sub-processor is bound by written data-protection obligations that provide a level of protection substantially equivalent to this DPA. The current list of authorised Sub-processors is not published publicly for security and confidentiality reasons but may be made available to Subscribers upon written request under a confidentiality agreement.<\/p>

1.9 \u201cSubscriber Data\u201d has the meaning given in the Agreement or, if none, means data submitted by or on behalf of the Subscriber to the Services under its Prime AI account.<\/p>

1.10 \u201cSubscriber Personal Data\u201d means the personal data contained within Subscriber Data.<\/p>

1.11 \u201cTerm\u201d means the period from the DPA Effective Date until the end of Prime AI\u2019s provision of the Services, including any post-termination period during which Prime AI may continue processing for transitional purposes.<\/p>

1.12 The terms \u201cpersonal data\u201d, \u201cdata subject\u201d, \u201cprocessing\u201d, \u201ccontroller\u201d, \u201cprocessor\u201d, and \u201csupervisory authority\u201d have the meanings given in the GDPR, and \u201cdata importer\u201d and \u201cdata exporter\u201d have the meanings given in the Standard Contractual Clauses.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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2. Data Processing Obligations<\/h6>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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2.1 Prime AI shall process Subscriber Personal Data solely for the purposes of providing the Services, performing its obligations under the Agreement, and complying with applicable law. For certain Services, such as Virtual Try On, AI Photoshoot and other visualisations, Prime AI may securely transmit Subscriber provided images to a trusted technology partner solely for transient processing required to generate results. Such images are processed momentarily and are not retained by Prime AI after completion, unless requested by Subscriber.<\/p>

2.2 Prime AI will process Subscriber Personal Data:<\/p>