Data processing agreement
The template we sign with a client whose company needs one: Plunge AI as the processor, the client as the controller, for the personal data Plunge AI Consulting handles while it does the client's work.
Version 2026-10-25 · Pending owner sign-off
In short: we process your people's data only to do the work you ordered and only as you instruct. We use the subprocessors on our security page, tell you before we add one, and you can object within 30 days. We help you answer requests, return and erase the data when you ask, and tell you without undue delay about a breach. This summary does not replace the page below.
Template — pending legal review. Signed copies on request at legal@plungeai.com. Where this template and a signed agreement differ, the signed agreement applies.
1. Parties
Controller: the client company named on the order form, acting through its sponsor.
Processor: PlungeAI, Inc. ("Plunge AI"), which runs Plunge AI Consulting.
This agreement is part of the terms and lasts as long as Plunge AI processes personal data for the controller under them.
2. Scope of processing
Subject matter
Scoping, proposing, building, testing, delivering and running the work the controller orders: Discover, Build, Connect and Run.
Data subjects
The controller's staff who use the portal or sign; the people who fill in the start form; people named in evidence or material the controller shares with us.
Categories of data
Names, work email addresses and roles; the start form's answers; the content of evidence, deliveries and comments; sign-offs, with the consent text, the time and a hash of the signer's IP address and browser; billing contact details. No special categories are needed, and the controller agrees not to share them.
Duration
While the controller is a client and until its data is erased (section 8).
3. Instructions
Plunge AI processes personal data only on the controller's documented instructions: the terms, this agreement, the signed order forms, proposals and change orders, and the decisions the controller's people make in the portal. Plunge AI tells the controller at once if it believes an instruction breaks data protection law.
People at Plunge AI who work on the controller's data are bound to confidentiality and see only the clients they work for. AI agents draft; the owner approves every text before it reaches the controller. Plunge AI does not train or fine-tune models on the controller's data.
4. Security
Plunge AI keeps the measures on the security page: databases and file storage of Plunge AI Consulting's own on Cloudflare, with a folder per client; each client sees only its own data; sign-offs that are never edited or deleted; links stored only as hashes; no secret value in our databases; cards held by Stripe. Plunge AI updates that page before it changes a measure in a way that lowers protection.
5. Subprocessors
The controller authorises the subprocessors listed at /security#subprocessors, each with its purpose and the data it sees. Plunge AI adds a row there before a new subprocessor sees any client data and tells the controller's sponsor by email. The controller may object within 30 days; the parties then find a way around it, or the controller may end the work under the terms. Plunge AI stays responsible for each subprocessor's performance.
6. Transfers
Plunge AI Consulting's workers run in Cloudflare's San Jose region, and its database primaries are in western North America. Where a transfer leaves the controller's jurisdiction, it is made under the subprocessor's standard contractual terms or another recognised mechanism, which Plunge AI names on request.
7. Assistance
Plunge AI helps the controller answer data subject requests: the sponsor downloads the controller's records as JSON from the portal; a correction is made on request; an erasure is section 8. Plunge AI helps with impact assessments and consultations with authorities as far as the processing described here needs it.
8. Deletion and return
At the end of the agreement, or whenever the controller asks, the sponsor downloads the export and Plunge AI erases the controller's data: its rows in all three databases and its file folder, as Privacy describes. What stays: signature records the law requires Plunge AI to keep, listed back to the controller; invoices and payment records at Stripe, kept for tax and accounting; and the Plunge AI platform's own run records, which follow the platform's retention. If Plunge AI stops the service, it gives at least 60 days' notice and a full export first.
9. Audit
On request, no more than once a year unless an authority requires it, Plunge AI gives the controller the information needed to show it meets this agreement: the security page as it stood, the subprocessor list, the controller's timeline and the log of AI actions that reached it. Plunge AI holds no third-party certification (certifications); if it gets one, the report stands in for the above.
10. Breach notice
Plunge AI tells the controller's sponsor without undue delay after it becomes aware of a personal data breach that affects the controller's data, with what happened, which data and people it touched, what Plunge AI did and what it recommends, and adds to it as it learns more. Report a suspected breach to legal@plungeai.com.