Data Processing Agreement

Part A. Application and acceptance

A.1 Definitions

GDPR terms keep their GDPR meaning. "Agreement" means the contract under which Stoa provides the Service: the Terms of Service accepted online, or a signed order form that refers to them. "Affiliate" means an entity that controls, is controlled by or is under common control with a party. "Customer Content" means the documents the Customer or its users place in the Service and everything Stoa derives from them. "Working day" means a day other than a Saturday, Sunday or public holiday in Finland.

A.2 Roles

For Customer Content and the data of the Customer's users in the Service, the Customer is the controller and Stoa the processor. The Customer's Affiliates using the Service under the Agreement are controllers too; the Customer acts for them. For data Stoa collects for its own purposes, Stoa is a controller and the Privacy Policy applies.

A.3 Execution

This DPA is accepted with the Agreement and deemed executed on the date the Agreement is accepted or signed; acceptance by an account administrator constitutes the Customer's signature of Annex I. On request, Stoa provides a PDF completed with the Customer's details and countersigned. A separate data processing agreement signed as part of an order form prevails over this page.

A.4 Precedence

On the processing of personal data, the Clauses in Part B prevail over Part C, and this DPA prevails over the Agreement (Clause 4).

A.5 Choices made in the Clauses

Where the Clauses offer a GDPR option and a Regulation (EU) 2018/1725 option, the GDPR option applies. The optional docking clause (Clause 5) is omitted; Affiliates are covered by A.2. In Clause 7.7(a), Option 2 (general written authorisation) applies with thirty (30) days' notice. Nothing else in Part B is altered.

Part B. Standard contractual clauses (Commission Implementing Decision (EU) 2021/915)

The text below is the Annex to Commission Implementing Decision (EU) 2021/915 of 4 June 2021, reproduced without modification save for the choices stated in A.5. Annex references are to Annexes I to IV of this DPA.

Section I

Clause 1. Purpose and scope

(a)The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

(b)The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.

(c)These Clauses apply to the processing of personal data as specified in Annex II.

(d)Annexes I to IV are an integral part of the Clauses.

(e)These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(f)These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2. Invariability of the Clauses

(a)The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b)This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3. Interpretation

(a)Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

(b)These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

(c)These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4. Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5. Docking clause (optional)

Not included. See A.5.

Section II. Obligations of the Parties

Clause 6. Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7. Obligations of the Parties

7.1. Instructions

(a)The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b)The processor shall immediately inform the controller if, in the processor's opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing

(a)The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b)The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person's sex life or sexual orientation, or data relating to criminal convictions and offences ("sensitive data"), the processor shall apply specific restrictions and/or additional safeguards.

7.6. Documentation and compliance

(a)The Parties shall be able to demonstrate compliance with these Clauses.

(b)The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c)The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller's request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d)The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e)The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7. Use of sub-processors

(a)GENERAL WRITTEN AUTHORISATION: The processor has the controller's general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least thirty (30) days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b)Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c)At the controller's request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d)The processor shall remain fully responsible to the controller for the performance of the sub-processor's obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

(e)The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8. International transfers

(a)Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

(b)The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8. Assistance to the controller

(a)The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b)The processor shall assist the controller in fulfilling its obligations to respond to data subjects' requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller's instructions

(c)In addition to the processor's obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

(d)The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9. Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a)in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

(b)in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller's notification, and must at least include:

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c)in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a)a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b)the details of a contact point where more information concerning the personal data breach can be obtained;

(c)its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller's obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

Section III. Final provisions

Clause 10. Non-compliance with the Clauses and termination

(a)Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b)The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

(c)The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

(d)Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

Part C. Supplementary terms

Added under Clause 2(b). They set the time limits the Clauses leave open and allocate liability, and are read so as to give the Clauses their full effect.

C.1 Sub-processors

The agreed list in Clause 7.7(a) is Annex IV, published at stoabuild.com/dpa with the date of its last change. Stoa gives the 30 days' notice by email to the Customer's account administrators and to any address the Customer names. The Customer may object in writing within that period on reasonable data protection grounds. If the objection is not resolved before the change takes effect, the Customer may terminate the Agreement, or the part of the Service that depends on the sub-processor, and Stoa refunds fees prepaid for the period after termination.

C.2 Data residency and international transfers

Customer Content, including derived data, chat history and AI inference, is stored and processed in the EU/EEA. The only processing outside the EU/EEA is the following, each stated against its provider in Annex IV, and none of it involves Customer Content:

• Authentication data (name, email address, session metadata) is held by the identity platform in the United States.
• Requests and responses pass through the edge network's data centre nearest the user, in transit only.
• Support engineers of the database provider may access the EU-hosted database from outside the EU/EEA, and the AI provider's support sub-processors may operate outside the EU/EEA, in each case under that provider's data processing terms.

Each transfer to the United States relies on the provider's EU-US Data Privacy Framework certification where it holds one and on the standard contractual clauses of Commission Implementing Decision (EU) 2021/914 in the provider's terms, which continue to apply on their own if the Framework ceases to be valid. Stoa provides the provider's transfer safeguards and its own assessment of them on request. Stoa makes no other transfer without the Customer's documented instruction.

C.3 Personal data breach notification

Stoa notifies the Customer of a personal data breach without undue delay and in any event within forty-eight (48) hours of becoming aware of it, by email to the Customer's named contacts and by telephone where the Customer has given a number for this purpose, with the content listed in Clause 9.2 as far as then known, the time of awareness, the data categories and number of data subjects affected as far as known, and the containment measures taken. Stoa updates the notification as information becomes available and provides a written report after its post-incident review. Stoa notifies supervisory authorities or data subjects only on the Customer's instruction.

C.4 Data subject requests and other assistance

Stoa forwards a data subject request it receives within two (2) working days and, where the Customer needs Stoa's help to locate, export, correct or erase a person's data in the Service, provides it within ten (10) working days. Stoa provides the information in Annex II and Annex III for the Customer's data protection impact assessments and answers reasonable security questionnaires. This assistance is free of charge; for manifestly excessive or repetitive requests Stoa may charge reasonable costs agreed in advance.

C.5 Audits

The audit right in Clause 7.6 is exercised in three tiers:

• Documentation, at any time: Stoa's security policies, this Annex III, its sub-processors' certifications and audit reports, and completed security questionnaires.
• Remote review, on thirty (30) days' notice: written questions and evidence review with the Customer or an independent auditor it mandates, answered within twenty (20) working days.
• On-site or system audit, once in any twelve (12) months on thirty (30) days' notice, by the Customer or an independent auditor that is not a competitor of Stoa and is bound by confidentiality, during working hours and without compromising other customers' data.

Remote reviews and on-site or system audits take place at the Customer's cost, including Stoa's reasonable time at its then-current rates, with the scope, timing and auditor agreed in writing before the audit begins. The Customer gives Stoa a copy of the audit findings. After a personal data breach affecting the Customer, or where a supervisory authority requires it, an audit may take place at any time on reasonable notice, each party bearing its own costs. Stoa remediates critical findings without delay and other findings on an agreed schedule. Sub-processor data centres are audited through their certifications and audit reports.

C.6 Return and deletion of data

The Customer's documents remain in its own systems; Stoa holds a copy and an index. Return under Clause 10(d) therefore takes place during the term: users can download original documents at any time, and Stoa produces a structured export (documents, metadata, chat history and citations) on request, free of charge, within thirty (30) days. A Customer that wants its data returned requests the export before the Agreement ends; Stoa delivers it even where delivery falls after the end of the term.

On termination or expiry, Stoa deletes all Customer Content from its production systems within thirty (30) days and provides a written certificate of deletion. Backup copies expire on their normal schedule within a further thirty (30) days and are not restored. Data that Union or Member State law requires Stoa to retain is kept only for that purpose and for as long as the law requires.

C.7 Technical and organisational measures

Annex III describes the measures in force. Stoa may update them provided the level of security is not materially reduced, and informs the Customer of a material change.

C.8 AI processing

The Service uses large language models to answer users' questions about Customer Content. Inference runs only in the EU region through the AI sub-processor in Annex IV. Customer Content, prompts and answers are not used to train, fine-tune or improve any model. The Service produces no scores, rankings, profiles, evaluations or predictions about natural persons, and no processing under this DPA is automated individual decision-making within the meaning of Article 22 of the GDPR. Stoa gives thirty (30) days' notice before changing the inference region or the AI sub-processor.

C.9 Confidentiality of personnel

Every Stoa employee and contractor signs a written confidentiality undertaking before receiving access. It covers Customer Content and personal data and survives the end of the engagement without time limit. Access by Stoa personnel to Customer Content is limited to named engineers, only for support, incident response or maintenance, and is logged.

C.10 Liability and indemnity

Neither party is liable to the other under or in connection with this DPA for indirect or consequential loss, including loss of profit, revenue, business, goodwill or anticipated savings, or for loss or corruption of data beyond the cost of restoring it from the most recent backup. Each party's total aggregate liability under this DPA and the Agreement together, except the Customer's obligation to pay fees, is limited to the fees paid or payable by the Customer in the twelve (12) months preceding the event giving rise to the claim. These exclusions and limitations do not apply to liability arising from wilful misconduct or gross negligence, to a party's deliberate disclosure of the other party's confidential information, or to liability that cannot be limited by law. Nothing in this DPA limits either party's liability towards data subjects under Article 82 of the GDPR.

Subject to this C.10, each party indemnifies the other against administrative fines and third-party claims to the extent caused by its own breach of this DPA or of the GDPR, provided the other party gives prompt notice, control of the defence and reasonable assistance.

C.11 Term, survival and change of roles

This DPA takes effect with the Agreement and lasts as long as Stoa processes personal data for the Customer, including the deletion period in C.6. Confidentiality, deletion, the certificate of deletion and liability survive. If the parties' roles change, they record the change in writing before the processing begins; this DPA continues to apply wherever Stoa acts as processor.

C.12 Changes to this DPA

Stoa may update Annex III under C.7 and Annex IV under C.1. Other changes reflect a change in law or in the Service and take effect after thirty (30) days' written notice by email. A change that materially reduces the Customer's rights or Stoa's obligations does not apply without the Customer's consent; a Customer that does not consent may terminate the Agreement before the change takes effect and receive a refund of fees prepaid for the period after termination. Every version carries a number, an effective date and a change log.

C.13 Governing law and disputes

This DPA and any dispute or claim arising out of or in connection with it are governed by the laws of Finland, excluding its conflict-of-law rules. Disputes are resolved in the courts of Finland, with the District Court of Helsinki as the court of first instance, without prejudice to the rights of data subjects and supervisory authorities under the GDPR.

C.14 Customer obligations

The Customer is responsible for the lawfulness of the processing it instructs, including its legal basis and the information given to data subjects; for its instructions complying with the GDPR; for the Customer Content it and its users place in the Service, including any special category data (Annex II); for the acts and omissions of its users and Affiliates as if they were its own; for granting and withdrawing access to folders and deactivating accounts; and for its authority to bind its Affiliates to this DPA.

Annex I. List of parties

Controller

Identity

The Customer identified in the Agreement, together with its Affiliates that use the Service under the Agreement.

Contact person

The administrator who accepted the Agreement, and any data protection contact the Customer names in writing.

Signature and accession date

The date the Agreement was accepted or signed (A.3).

Processor

Identity

Stoa Technologies Oy, Business ID 3633842-5, Kampinkuja 2, 00100 Helsinki, Finland.

Contact person

Data protection contact, eino@stoabuild.com. Stoa is not required to appoint a data protection officer and has not appointed one.

Signature and accession date

Signed by Stoa on 11 September 2026 for version 2.0; countersigned on the Customer's accession date on request.

Annex II. Description of the processing

Categories of data subjects

• Users the Customer authorises: employees of the Customer and its Affiliates, and the contractors, consultants and other project participants it invites.
• Persons named in Customer Content: employees and representatives of the Customer, its clients, designers, authorities, subcontractors and suppliers, site personnel, inspectors, and any other person appearing in construction project documentation.

Categories of personal data

• Account data: name, work email address, organisation, role, authentication and session metadata, and the user's activity in the Service.
• Task data: tasks a user creates and assigns to a colleague, and the resulting notifications.
• Personal data in Customer Content: names, job titles, employers, contact details, signatures, identifiers and other information about a person appearing in the documents. Incidental to the documents; not extracted into profiles.
• Derived data: extracted text, page and section structure, embeddings and search indexes.
• Chat history: questions, generated answers and the citations that link them to source pages.

Sensitive data and safeguards

The Service is not intended to process the special categories of data in Article 9 of the GDPR or data relating to criminal convictions. Such data may appear incidentally in Customer Content, at the Customer's discretion and responsibility. Safeguards applied to all Customer Content: strict purpose limitation; folder-level access under which a document is reachable only by users the Customer has granted access to that folder; encryption in transit and at rest; no use for training; no profiling; logging of administrative access; deletion with the rest of the Customer Content.

Nature of the processing

Collection from users and connected document systems; storage; conversion and rendering; extraction of text and structure; indexing and embedding; retrieval limited to the folders the user may access; generation of a cited answer by a large language model in the EU; display; sharing within the Customer's workspace under its access grants; transactional email; export; deletion.

Purpose

To provide the Service: letting the Customer's authorised users search, retrieve and obtain cited answers about project documentation to which they have been granted access, and coordinate tasks. No other purpose; in particular no processing of Customer Content for Stoa's own purposes, no marketing and no model training.

Duration

The term of the Agreement, plus the deletion period in C.6 of thirty (30) days and the backup expiry of thirty (30) days.

Processing by sub-processors

Subject matter and nature are stated beside each sub-processor in Annex IV. The purpose is the provision of the Service and the duration is that of Stoa's own processing, unless Annex IV states a shorter retention.

Annex III. Technical and organisational measures including technical and organisational measures to ensure the security of the data

The measures in force at the effective date. Stoa's security practice is aligned with ISO/IEC 27001:2022; Stoa does not hold a certification. Physical and infrastructure controls are those of the certified providers in Annex IV.

• Encryption: TLS 1.2 or higher on every connection; AES-256 encryption at rest on all data stores and backups; secrets held in a managed secret store, never in source code, and rotated on personnel change, on suspicion and at least annually.
• Identification and authorisation: authentication delegated to a managed identity platform, with enterprise single sign-on against the Customer's own identity provider and its multi-factor and conditional access policies. Access to Customer Content is denied by default and granted by the Customer per folder; the permitted folder set is applied inside every retrieval query, so content outside a user's grants is never retrieved or cited. Every authorisation check fails closed.
• Personnel access: administrative access to Customer Content limited to named engineers on personal accounts with multi-factor authentication, only for support, incident response or maintenance, logged and reviewed at least annually.
• Confidentiality, integrity and availability: production separated from development and test with separate credentials and data; the AI agent has no write path to source documents, permissions or external systems; edge protection against denial of service; automated dependency and vulnerability scanning with remediation prioritised by severity.
• Restoration: automated encrypted backups held separately from the running system, with point-in-time recovery for the database; recovery time and recovery point objectives as an Order Form provides; restore tested at least annually.
• Testing and evaluation: automated tests on the access-control surface asserting fail-closed behaviour, run on every change; a change to the access-control surface cannot merge unless its specification changes with it; a management review of these measures at least annually.
• Physical security: no premises of Stoa hold customer data; provider data centres evidenced by ISO/IEC 27001 and SOC 2 reports; encrypted endpoints, and a rule that Customer Content is never downloaded, printed or moved outside approved systems.
• Event logging: authentication events; a retrieval trail for every question (documents retrieved, citations, answer); AI activity traces held on Stoa's own EU infrastructure for twelve (12) months unless otherwise agreed; provider audit logs. Timestamps in UTC; no secrets in logs; used for security and traceability, never to monitor a person's performance.
• Governance: a management-approved security policy and a named owner; deployment from the build pipeline after automated checks, with environment-scoped credentials; a signed confidentiality undertaking before access and security training at onboarding for every employee and contractor; every supplier bound by a data processing agreement before use.
• Minimisation and retention: each sub-processor receives only what its function needs; personal data in Customer Content is returned only inside cited source text; data is retained for the term and deleted under C.6 with a certificate of deletion.
• Portability and erasure: documents downloadable throughout the term; structured export on request (C.6); accounts deactivated by the Customer's administrator with immediate effect; a person's data located and corrected or erased with Stoa's help (C.4).

Assistance to the Customer (Clauses 8(d) and 9)

• Data subject requests: search across a tenant's documents, chat history and account records for a named person, and export, correction or deletion of what is found, within the times in C.4.
• Data protection impact assessments: Annex II, Annex IV and this Annex, and answers to reasonable questions about them, on request and free of charge.
• Security: this Annex, sub-processor certifications and answers to security questionnaires.
• Breaches: the notification in C.3; the retrieval trail and AI activity traces to establish which data and persons were affected; a written post-incident report; and reasonable assistance with the Customer's notifications.

Detailed security documentation is provided under a non-disclosure agreement on request.

Annex IV. List of sub-processors

The Customer has authorised the sub-processors below under Clause 7.7(a). List last changed on 11 September 2026. Each is engaged under a data processing agreement imposing, in substance, the same obligations as this DPA, and publishes its own list of providers, available on request.

The Google Gemini and Anthropic Claude models are served by Google Cloud on its own infrastructure. Anthropic is not a sub-processor and does not receive prompts, retrieved content or answers. Amazon Web Services hosts the database provider's service and is that provider's sub-processor, not Stoa's. Systems the Customer connects to the Service (its own document repositories and identity provider) are the Customer's processors, not sub-processors of Stoa.

Stoa's product analytics provider receives users' names and email addresses for Stoa's own purposes as controller (A.2). It is therefore not a sub-processor under this DPA; it is named, with its location and transfer safeguards, in the Privacy Policy, and a Customer may have analytics disabled for its workspace.

Contact

Notices, data subject requests, security questions and breach reports:

Stoa Technologies Oy (Business ID 3633842-5)
Data protection contact
Kampinkuja 2
00100 Helsinki
Finland
Email: eino@stoabuild.com

Change log

• Version 2.0, 11 September 2026: Adopted the Commission's standard contractual clauses (Decision (EU) 2021/915) with supplementary terms: 48-hour breach notification, 30 days' sub-processor notice with a right to object, 10 working days for data subject request assistance, a three-tier audit right at the Customer's cost, export during the term and deletion within 30 days of termination with a certificate, an AI clause, an exclusion of indirect loss and a liability cap with a mutual indemnity, Customer obligations, precedence, term and survival, governing law and versioning. Added the description of processing, the technical and organisational measures and the full sub-processor list as annexes.
• Version 1.0, January 2026: First published version.