Draft, pending counsel review
This document is published in draft so that it can be read before a contract conversation. It has not yet completed review by external counsel and will be superseded by the reviewed version.
Data Processing Agreement
Last updated: [CONFIRM]
The DPA is executed before a single conversation is captured, including in a pilot. The full document is available below; the table summarises what it commits us to, so that a reviewer can decide whether the full text is worth their afternoon.
Get the document
The executable DPA, including the standard contractual clauses and the subprocessor annex, is sent by a person rather than served as an anonymous download, so that we know who is reviewing which version.
Summary table
| Roles | The retailer is the controller. Gaincraft is the processor, acting only on the retailer’s documented instructions. |
|---|---|
| Subject matter | Capture, transcription, redaction and behaviour scoring of in-store selling conversations at designated counters. |
| Data categories | Audio of customer and associate speech; redacted transcripts; derived behaviour scores; associate identifiers by seat and shift; roster data. |
| Special categories | Not intentionally processed. Clinical areas and exam rooms are excluded zones. Incidental special-category speech is redacted where detected. |
| Biometric data | None. No voiceprints or voice embeddings are created or stored at any stage, including model training. No camera or image sensor exists in any device. |
| Data subjects | Retail customers in capture zones; associates assigned to capturing seats. |
| Retention | Audio auto-deleted at the end of the configured window: thirty days by default, seven days or twenty-four hours on request. Derived data for the contract term, then exported or destroyed on instruction. |
| Security measures | Encryption in transit and at rest, least-privilege access, redaction at ingestion, and an audit log of every access including Gaincraft staff access, available to the retailer. |
| Subprocessors | Published list, advance notice of material changes, right to object. No subprocessor may use retailer data to train its own models. |
| Transfers | Standard contractual clauses, plus regional residency selection for processing and backups. |
| Data subject requests | Gaincraft assists the retailer in responding within the statutory period and does not respond directly unless instructed. |
| Breach notification | Notification to the retailer without undue delay and within [CONFIRM] hours of becoming aware, with the facts known at that time. |
| Audit rights | Certification reports on request under NDA, plus an audit right exercisable on reasonable notice as set out in the agreement. |
| Deletion on termination | Deletion or return of all data at the retailer’s election, with written confirmation of deletion. |
The summary is provided for orientation. Where it differs from the executed document, the executed document governs.
Related material
The consent framework, the state consent map, the subprocessor list and the legal review page are public and can be forwarded without a covering explanation.