Neurocity Data Processing Agreement
This agreement is part of the Neurocity Terms of Service between Burrell Technologies, LLC ("Processor", "we") and the Customer ("Controller", "you"). Where they conflict about personal data, this agreement wins.
1. Roles
You decide why and how personal data in your Neurocity is processed. We process it only for you, as your service provider and processor (including as a "service provider" under the California Consumer Privacy Act).
2. What we process
| Purpose | Providing the Service: connecting your systems, storing and showing your data, automations and actions you set up, the client portal, AI features you turn on, support |
|---|---|
| Kinds of data | Whatever you put in or connect. Typically names, work contact details, user accounts and sign-in activity from your systems, device details, tickets and messages, and business records about your clients (cases, accounts, jobs, policies, invoices) |
| People concerned | Your staff; your clients and their staff; other people in your records |
| How long | While you have a subscription, then 30 days, then deletion (backups expire within 35 days). Event data (sign-ins, audit records from connected systems) expires sooner, by your company's retention setting |
You won't give us special categories of data (health, biometric and the like) unless the Service is set up for it and we've agreed in writing.
3. Our commitments
We will:
- process personal data only on your documented instructions (this agreement, the Terms, and your use and settings in the Service), and tell you if we think an instruction breaks the law;
- make sure everyone who processes it is bound to confidentiality;
- keep the security measures in section 6 in place;
- use subprocessors only as section 5 allows;
- help you answer requests from people exercising their rights, mainly through the Service's own features (finding, exporting, correcting and deleting records);
- tell you about a personal data breach without undue delay, and within 72 hours of confirming it, with what we know and what we're doing, and keep you updated;
- help you with impact assessments and regulators where they concern our processing;
- delete or return your data when the subscription ends, as section 2 says;
- give you the information you need to check we're meeting this agreement (section 7);
- not sell your data, not use it for our own purposes, and not combine it with other customers' data. Each company's data is kept in its own database.
4. AI processing
If you turn on AI features, the parts of your data needed to answer a request are sent to Anthropic to generate the response. Anthropic processes them as our subprocessor, under terms that don't allow using them to train its models. AI reads data with the requesting person's permissions only and can't change your systems on its own. You can turn AI off at any time.
4a. Exposure (if you add it)
Exposure reads settings and sharing information from the systems you connect, to find what's exposed: which apps have access to your Microsoft 365 or Google Workspace data and who let them in; which files are shared with anyone (their names, owners and folders, never their contents or sharing links); Copilot Studio agents and Power Pages sites; and your domains' public DNS records and public certificate logs. The optional file scan can read every file in a Microsoft 365 directory but only checks how each is shared. Fixes change your systems only when someone you allow approves them (or when you turn on approving them automatically), and are recorded in your audit log. Turning the file scan off deletes what it found.
5. Subprocessors
You authorize these subprocessors:
| Subprocessor | Purpose | Location |
|---|---|---|
| Microsoft Corporation (Azure) | Hosting, databases, key vault, email delivery | United States (Central US) |
| Cloudflare, Inc. | Network delivery and protection | Global network |
| Anthropic, PBC | AI features (only if turned on) | United States |
We'll give at least 30 days' notice before adding or replacing a subprocessor. If you object on reasonable data protection grounds and we can't resolve it, you may end the affected part of the Service and get a refund of prepaid fees for it. We hold each subprocessor to data protection terms at least as protective as these, and we're responsible for its work.
6. Security measures
- Isolation: each company has its own database; row-level security on every table; the application can't bypass it; every connection checks it's reaching the right company's database.
- Access: staff and client access by invitation and role, decided by the company; client users see only their own client's records; every sign-in, data view, change and action is written to a tamper-evident (hash-chained) audit log.
- Secrets: keys to connected systems are sealed in Azure Key Vault and opened only by the background worker; the web application can't read them back. No passwords are stored.
- Encryption: in transit (TLS) and at rest.
- Infrastructure: changes only through reviewed, recorded deployments; production databases without password sign-in; Neurocity staff access to production limited and recorded.
- Resilience: point-in-time database restore for 35 days.
- Changes to your systems: risk-tiered actions with approvals, an impact preview and undo where possible.
We may update these measures as long as protection doesn't decrease.
7. Audits
On request (at most once a year, unless there's been a breach or a regulator asks), we'll answer reasonable security questionnaires and provide our available security documentation.
8. Liability
Liability under this agreement is subject to the limits in the Terms of Service.
Signed for Burrell Technologies, LLC ______________________ Date ________
Signed for the Customer ______________________ Date ________