Data processing agreement

This agreement

This page is our data processing agreement. It forms part of our terms of service, and your organisation accepts it when it accepts those terms. Where this agreement and the terms say different things about personal data, this agreement applies.

Who does what

Your organisation is the controller. It decides why and how the personal data in its uploads is used.

Copytone, run by Owen Fisher, is the processor. We handle that data only to run Copytone for you, and only as this agreement and your instructions say.

For our own records about you, such as account and billing details, we are the controller. Our privacy policy covers those.

Questions about this agreement go to support@copytone.co.

The processing

What it is for

Running Copytone for your organisation: reading your guides, preparing what your customers said, checking your copy, writing suggestions and starting points, and keeping your team's work.

What we do with the data

Store it. Take names and contact details out of customer exports. Count words. Tag what customers said, by keyword, with the step they were at and how they felt. Send guides, copy and customer words to our AI model provider, with what is described under What the model sees taken out first. Show the results to your team in the studio. Delete it.

Whose data

Your customers and patients, in the reviews and comments you export. People named in your guides, emails and documents. The people on your team who use Copytone.

What kinds of data

Whatever your uploads hold. In customer exports that is usually names, contact details, order and reference numbers, and what people said about their experience. For your team, names, work email addresses, a record of who made which change and when, what they say to each other in the studio's comments and team chat, and which page each person has open while they are in the studio.

Special category data

Information about health, in reviews and comments. See Health data, below.

How long

For as long as your subscription runs, and until deletion at the end. If your organisation never subscribes, until an owner deletes it or you ask us to. Raw uploads are deleted as soon as Copytone has read them. The copy of each export with names and contact details taken out is kept, because the studio is rebuilt from it. From uploaded emails and documents we keep their lines of text, with email addresses, phone numbers and titled names such as “Dr Smith” taken out. They are your organisation's own writing, so its own names stay.

What the model sees

Before anything goes to our AI model provider, some of it is taken out automatically, and what is taken out differs by kind:

• Guides: email addresses and phone numbers. Other names in a guide stay, because a guide is full of the names of your brand, your products and your services.
• Copy you upload or paste: email addresses, phone numbers, and names with a title in front of them, such as Dr Jane Smith. Other names stay, because the copy is your own writing.
• Pages read from your website: nothing, because they are already public.
• Customer words: names and contact details, as described under Security, below.

Automatic removal can miss things, so we protect what is sent as personal data.

Your instructions

We act only on your documented instructions. Our terms of service, this agreement, the settings you choose and what you ask Copytone to do are those instructions.

If we think an instruction breaks data protection law, we tell you. If a law requires us to process your data in some other way, we tell you before we do, unless that law forbids telling you.

Confidentiality

Only people who need access to run Copytone for you can reach your data. Each of them is bound to keep it confidential.

Security

We protect your data with measures that fit the risk, and health data carries more risk. The measures include:

• Capitalised names, email addresses, links, social handles, phone numbers in UK, US and Australian formats, and long numbers come out of customer exports on arrival, before anything else is done with them. Automatic removal can miss things, so we protect what is left as personal data.
• Raw uploads are deleted as soon as Copytone has read them, and never copied into a backup.
• Every connection to Copytone is encrypted.
• Your studio is shown only to your team, in the roles your owners gave them. We can view it, without changing anything, to give support.
• Your data is kept apart from other customers' data.
• Passwords are kept only in a scrambled form that cannot be turned back into the password.
• Only people who need access can reach the server, which sits in a data centre in Helsinki, Finland.
• A nightly backup, encrypted, kept on the same server for up to six months. Data deleted from Copytone can stay in a backup for up to six months, where nobody uses it, and is then gone. Raw uploads are never backed up.

If we find a personal data breach that affects your data, we tell you without undue delay, with what we know, so you can meet your own duties.

Health data

Reviews of health services often mention health, which is special category data. Before your organisation uploads it, it must have a lawful basis and a condition under Article 9 of UK GDPR. Copytone does not choose that condition for your organisation, because it depends on who you are and why you hold the data.

Named health conditions from a set list come out on arrival, with names and contact details. We keep what customers wrote, with those taken out, and the word counts made from it. The studio shows only sentences that had nothing taken out.

Automatic removal can miss things. So we protect everything we keep from your uploads as personal data until it is deleted, and we never try to find out who wrote a review.

If your organisation carries out a data protection impact assessment, we give you the information you need for it.

Sub-processors

You give us general permission to use the sub-processors listed on our sub-processors page.

Before we add or replace one, we email your organisation's owners and update that page at least 14 days before the new one starts work. You can object in that time. If we cannot resolve a reasonable objection, you can end your subscription, and we refund any period you paid for and did not use.

Each sub-processor is bound by a written contract that puts data protection duties on it that match this agreement. We remain responsible to you for its work.

Transfers outside the UK

Your data is stored in Finland, which UK law recognises as giving adequate protection. Some sub-processors are based outside the UK and the European Economic Area, and each one's safeguard is on the sub-processors page.

We run Copytone from Thailand, and reach your data there only to run and support Copytone. If your organisation needs the UK International Data Transfer Agreement in place for that, email support@copytone.co and we sign it with you.

People's requests about their data

If someone asks us to see, correct or delete their data in your uploads, we pass the request to you without undue delay. We do not answer it ourselves unless you tell us to.

We help you answer the requests people send you. Names and contact details come out on arrival, so we often cannot link what we keep to one person. When that is the case, we tell you, so you can say so in your reply.

Helping with your other duties

When you need it, we give you the information we have to help you keep data secure, deal with a breach, carry out an impact assessment, or consult the Information Commissioner's Office.

At the end

An owner can delete all of your organisation's data from Settings when no plan is running. When your subscription ends, you can ask for a copy first, and we delete the rest within 30 days after the subscription ends, unless the law requires us to keep it. If your organisation never starts a subscription, its data stays until an owner deletes it from Settings, or you ask us to delete it. Backups clear it within six months after it is deleted.

Audits

We give you the information you need to show that we keep to this agreement. We answer written questions first. If that is not enough, you, or an auditor you choose who is bound to confidentiality, may audit how we handle your data.

An audit needs 30 days' written notice, and can happen once in any 12 months, or again after a breach that affects your data. You pay for it, unless it finds that we seriously broke this agreement.