Phirmy

DRAFT · Version DRAFT-2026-10-25

Data Processing Addendum

DRAFT FOR LAWYER REVIEW. These placeholders are not approved legal terms. Business identity, jurisdictions, lawful bases, subprocessor commitments and statutory rights require review before public launch.

Processing schedule

DRAFT: Counsel must define controller/processor roles, processing instructions, purposes, data subjects, personal-data categories, duration and approved subprocessors for the final deployed service.

Required commitments

DRAFT: Supply security, confidentiality, assistance, breach notification, deletion/return, audit, international-transfer and subprocessor-change commitments. This placeholder is not an executed DPA or an assertion that these contractual commitments have been approved.