Data Processing Agreement
Last Updated: January 2025
This Data Processing Agreement ("DPA") forms part of the Terms of Service between number7even UG (haftungsbeschränkt) operating as VoiceCosmos² ("Processor") and the Customer ("Controller") to reflect the parties' agreement with regard to the Processing of Personal Data.
1. Definitions
Terms used in this DPA have the meanings set forth in this DPA. Capitalized terms not otherwise defined herein shall have the meaning given to them in the EU General Data Protection Regulation 2016/679 ("GDPR").
- "Personal Data" means any information relating to an identified or identifiable natural person.
- "Processing" means any operation performed on Personal Data.
- "Sub-processor" means any third party engaged by Processor to Process Personal Data.
- "Data Subject" means the individual to whom Personal Data relates.
2. Processing of Personal Data
2.1 Processor's Role
Processor shall Process Personal Data only on behalf of and in accordance with Controller's documented instructions and shall not Process Personal Data for any other purpose.
2.2 Nature and Purpose
The nature and purpose of Processing by Processor shall be to provide the VoiceCosmos² AI voice assistant services as described in the Terms of Service.
2.3 Duration
The duration of Processing shall be for the term of the Agreement between the parties.
3. Categories of Data and Data Subjects
Categories of Data
- • Voice recordings and transcriptions
- • Contact information (names, phone numbers)
- • Communication preferences
- • Appointment and scheduling data
- • Business interaction history
- • Custom data fields as configured
Categories of Data Subjects
- • Controller's customers
- • Controller's prospects
- • Controller's employees (if applicable)
- • Other individuals who interact with Controller's AI assistants
4. Processing Activities
Voice Data Processing
- Real-time voice conversation processing
- Voice-to-text transcription
- Natural language understanding
- Sentiment analysis and intent detection
Customer Data Management
- Contact information storage
- Conversation history archival
- Analytics and reporting generation
- Integration data synchronization
Technical Operations
- System performance monitoring
- Error logging and debugging
- Load balancing and optimization
- Backup and disaster recovery
5. Security of Processing
Processor shall implement and maintain appropriate technical and organizational measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
6. Sub-processors
6.1 Authorized Sub-processors
Controller agrees that Processor may engage Sub-processors to Process Personal Data. A current list of Sub-processors is available at:
6.2 Sub-processor Requirements
Processor shall ensure that any Sub-processor is bound by written agreement to provide at least the same level of data protection as required by this DPA.
7. Data Subject Rights
Processor shall, to the extent legally permitted, promptly notify Controller if it receives a request from a Data Subject to exercise their rights under GDPR. Processor shall assist Controller in fulfilling its obligations to respond to such requests.
Data subject rights include: access, rectification, erasure, data portability, restriction of processing, and objection to processing.
8. International Data Transfers
Transfer Mechanisms
Any transfer of Personal Data outside the EEA shall be subject to appropriate safeguards as required by GDPR, including:
- • EU Standard Contractual Clauses
- • Adequacy decisions by the European Commission
- • Binding Corporate Rules (where applicable)
- • Other valid transfer mechanisms under GDPR
9. Audits and Information
Processor shall make available to Controller all information necessary to demonstrate compliance with this DPA and allow for audits, including inspections, by Controller or an auditor mandated by Controller.
Controller agrees to provide reasonable notice of any audit and to conduct audits during normal business hours in a manner that minimizes disruption to Processor's business operations.
10. Personal Data Breach
Processor shall notify Controller without undue delay and in any event within 72 hours after becoming aware of a Personal Data Breach. Such notification shall include:
- • The nature of the breach including categories and approximate number of affected Data Subjects
- • The likely consequences of the breach
- • Measures taken or proposed to address the breach
- • Contact details for more information
11. Deletion and Return of Personal Data
Upon termination of the Agreement, Processor shall, at Controller's option, delete or return all Personal Data to Controller and delete existing copies unless EU or Member State law requires storage of the Personal Data.
Contact Information
Data Protection Officer
number7even UG (haftungsbeschränkt)
Email: dpo@voicecosmos.com
Phone: +49 172 893 723 30
Address: Eisolzriederstrasse 12, 80999 Munich, Germany