Studio data processing terms (DPA)
These terms form part of the Spotter terms between the studio ("you") and Trust Gem (Shunya Bots) ("we"). They meet UK GDPR and EU GDPR Article 28.
Roles. For personal data of your enquirers and contacts that Spotter handles ("Enquirer Data"), you are the controller and we are your processor. For your own staff account data (name, email, login), we are the controller.
Subject matter and details
| Item | Detail |
|---|---|
| Purpose | capture enquiries from your form, store them in your inbox, draft replies and follow-ups, show reminders and funnel counts, export and delete |
| Data subjects | people who enquire with your studio; your staff users |
| Data | name, phone or email, class of interest, preferred time, goal, message text, enquiry status and notes, technical data (IP address, browser details, spam-check signals) |
| Special-category data | not requested. May be volunteered in free text (see section 4) |
| Duration | while your account is open, then deletion as below |
Our commitments
- Instructions. We process Enquirer Data only to provide Spotter as you configure it, and on your other documented instructions, unless the law requires otherwise. We will tell you if we think an instruction breaks the law.
- Confidentiality. Only we, bound by confidentiality, can access it, and only as needed.
- Security. Appropriate technical and organisational measures, including invite-only sign-up, mandatory TOTP, hashed session tokens and invite codes, encrypted connections, separating each studio's data by studio, spam protection and rate limits, and least-privilege access.
- Sub-processors. You authorise:
| Sub-processor | What it does | Data | Location |
|---|---|---|---|
| Cloudflare, Inc. (Pages, Pages Functions) | hosting and application | all Spotter data in use | Cloudflare global network |
| Cloudflare, Inc. (D1) | database and its 7-day restore history | all stored Spotter data | European Union (D1 EU jurisdiction) |
| Cloudflare, Inc. (Workers AI) | AI model provider: drafts replies from the enquiry and your knowledge base. Inputs and outputs are not kept after the response, and are not used to train models | enquiry text and knowledge base, per request | Cloudflare global network (region not fixed) |
| Cloudflare, Inc. (Turnstile) | spam protection on the form | IP address, TLS fingerprint, browser details, site key, origin | not stated by Cloudflare |
| none. Spotter sends no email; your staff send replies from your own accounts | n/a | n/a |
We will tell you before adding or replacing a sub-processor, and you may object by closing your account. We impose equivalent data-protection terms on sub-processors.
- Assistance. We help you, as far as we reasonably can, with enquirers' rights requests (Spotter has export, delete and do-not-contact tools), with security, breach notices and impact assessments.
- Breaches. We tell you without undue delay after we become aware of a personal data breach affecting Enquirer Data.
- Deletion. When your account closes, we delete or return (at your choice, as CSV) Enquirer Data within 30 days, unless the law requires us to keep it. Database restore history expires after 7 days (section 5). Application logs are switched off.
- Audit. We make available the information reasonably needed to show we meet these terms.
- International transfers. Enquirer Data is stored in the location shown above, but Cloudflare's global network (including AI drafting and spam checks) may process it outside the UK, EU and your country, including in the US. Where UK or EU transfer rules apply, we rely on an appropriate safeguard: the EU Standard Contractual Clauses, with the UK Addendum or the UK International Data Transfer Agreement for UK data, or an adequacy decision or framework certification where it covers the provider.
Your commitments
- You have a lawful basis to collect and use Enquirer Data, and you give enquirers a privacy notice (section 2 is a template).
- You keep the AI and form wording (sections 3 and 6) visible.
- You check every AI draft before you send it. You are responsible for what you send.
- You are responsible for any Article 9 condition for health data that enquirers volunteer (section 4).
- You don't use Spotter for studios or enquirers in India.
Liability. Our total liability under the Spotter terms, including these data terms, is limited to the fees you paid us for Spotter in the 12 months before the event giving rise to the claim. Nothing limits liability for fraud, for death or personal injury caused by negligence, or for anything that cannot legally be limited, including non-excludable consumer rights (such as under the UK Consumer Rights Act 2015 and the Australian Consumer Law guarantees).
Fees and tax. Spotter takes no payments in phase 1. We do not currently charge GST. If GST becomes payable on our fees, we will give you at least 30 days' notice before it applies.