Approved for the pilot, 12 Oct 2026. Version dated 10 October 2026.
Company particulars will be completed before an agreement is concluded
Download draft agreement (PDF, EN)
The customer identified in the acceptance record acts as controller or as a processor authorized by the controller. The entity providing Patternward, identified in the company particulars, acts as processor or subprocessor respectively. Complete party details, verify signatory authority and finish legal review before concluding the agreement. This draft is not an executed agreement.
Processing covers the identified Patternward workspace, analysis of owned ads and posts, idea planning, creative preparation, calendars, reports, exports and contact with authorized users. It lasts for service delivery and the return or deletion period in Annex 2; it does not permit reuse after these operations end.
Processing follows this agreement, workspace settings and instructions from authorized people, including transfer instructions. Additional instructions must be recorded. An instruction considered unlawful requires notifying the customer and suspending its execution. Processing required by law without instructions requires prior notice unless the law prohibits it.
Only authorized people with necessary duties receive access, subject to confidentiality commitments or a relevant statutory obligation. The customer manages its user roles. Membership removal revokes access, sessions and attributed keys. One customer’s data is not used to assess another customer or train models.
Annex 3 separates implemented application measures from service environment measures awaiting verification. Safeguards require a risk assessment under GDPR Article 32. Neither a design description nor a local test is a certification or independent security audit.
Taking account of the processing and available information, the processor assists with individual rights, impact assessments, supervisory consultation, data security and GDPR Articles 32-36 duties. Individual requests are referred to the customer; the processor does not answer on its behalf without instructions unless required by law. Practical scope and any assistance charges are agreed without restricting statutory obligations.
After becoming aware of a breach affecting entrusted data, the processor notifies the customer without undue delay through its recorded contact address. It supplies available incident details, affected data and people, possible consequences, actions taken and a contact. Missing information does not delay the first notice; updates follow as available. The controller’s 72-hour deadline is not a processor waiting period.
The customer gives general written authorization only for services admitted in approved Annex 4. Listing a planned or disabled vendor does not authorize processing. Notice of an addition or replacement is sent at least 30 days before the change, allowing a reasoned objection in that period. If unresolved, the affected service is suspended or ended. Subprocessors accept equivalent protection duties; Patternward remains responsible to the customer for performance.
Annex 4 records current and planned locations; no general EU-only processing claim is made. A global AI choice requires an informed owner decision for each workspace and does not replace a GDPR Chapter V transfer basis. An abuse-log exemption request is not a granted exemption. Transfers outside the EEA require a verified basis and safeguards in advance.
The customer can download an offline archive and request deletion of owned data. An owner or administrator request allows two weeks for export or withdrawal before the scheduled operation revokes access and deletes active data. Backups expire separately on the recorded date. A request receipt does not prove completion. Minimal deletion receipts retain no deleted content. Statutory exceptions require a basis, scope and duration; shared market observations are not customer-entrusted data.
The processor supplies information needed to demonstrate GDPR Article 28 compliance and enables audits, including inspections by the customer or its authorized auditor. Timing, scope and confidentiality are agreed without excluding statutory duties or urgent incident inspection. Material deficiencies and remedial action are recorded.
Before the trial starts, the owner confirms authority and accepts an exact agreement version with its annexes. The record includes text, version, SHA-256 digest, owner identity and acceptance time. A PDF copy is available in the workspace; this is not a qualified electronic signature. Acceptance is unavailable until company particulars and legal review are recorded.
Operations include receiving, storing, organizing, analyzing, sharing with authorized people, exporting and deleting. Customer users: name, email, role, account identifier and activity records. Customer-owned ads and posts: text, media, publication links, aggregate measurements, plans and reports; material may contain likenesses or other personal data. Opt-in beta creators: profile, city, topics, formats, self-declared rates, briefs and messages; statistics only from voluntarily connected accounts with separate consent. Early access sign-ups: email, selected feature, language and consent record with email confirmation. Patternward separately controls its own early access registrations and creator recruitment; this DPA covers them only where actually entrusted by the customer. Special-category and criminal-conviction data are outside the agreed scope and should not be entered.
Own data: default active subscription plus 90 days after it ends, subject to the recorded workspace policy. Market measurements and captures: 13 calendar months, then deletion with a receipt; ad takedown requests have a 72-hour deadline. Own-data deletion follows the two-week window described above, with a separate backup-expiry date. The ZIP archive includes the available signed processing agreement with its receipt, plan and report PDFs and their data, approved creative media, results and calendar CSV, brand kit and brand voice. It excludes shared market data and credentials. Record covered workspaces, customer contact and any variations before signing.
Implemented application controls: encrypted connected-account credentials; current membership and role checks on reads and changes; workspace isolation and denial of foreign workspaces; protection against forged change requests; selected activity and acceptance records; document versioning; deletion scheduling and execution receipts; separation of own, market and showcase data; generator input and output checks against market wording. Backup and restore tools include the database, evidence and publication media; restored access stays quarantined until explicit regrant. Operational confirmation needed: disk encryption, secure connection configuration, administrative access limits, actual backup execution and location, restore exercise, staff confidentiality and incident procedure. A tool’s implementation does not prove production operation.
The following list uses the shared provider inventory with its date and change history. Before signing, confirm the entities actually authorized, data, locations, transfer bases and notice contacts. The unconfirmed pilot region and identity terms must be resolved before entrusting data; planned services are not active subprocessors.
Last changed:
Pilot hosting, database and files
Planned application, database, file and backup hosting
Transactional messages, subscription confirmations and notifications
Analysis and text or images from customer-owned data; market pattern analysis without copying ads
Identity, sign-in, sessions, email verification, multi-factor authentication and invitations
Payments and settlements after an agreement
Judgments over public market data; customer data (brand material, drafts, questions and support tickets) only with that workspace’s “Best available model” opt-in.
Image and video generation from owned brand material. Competitor material never enters generation.
Polish narration with authorized voices and script verification. Competitor material never enters generation.
Video and narration from owned material after explicit voice selection. Competitor material never enters generation.
Video from owned product photos. Competitor material never enters generation.
Optional publication of approved owned brand creatives, post copy and schedules; account identifiers and publication receipts. No competitor data or media.
AI assisted copy drafting, used only when enabled for your workspace.
Platform usage analytics, only with consent to optional analytics.
Support in Polish: [email protected].
