Data Processing Agreement.

1. Roles & scope

You are the Controller of the content you upload and generate. Lunar8Ops acts as your Processor, processing that content only to provide the Service and only on your documented instructions (which include your use of the product's features).

2. Nature of processing

Lunar8Ops stores your knowledge base and data tables to make them retrievable, distills voice-training uploads into your Twin and then deletes the raw files (within 24 hours), and sends the specific content a request requires to AI inference providers to produce the output you ask for. The categories of data are those you choose to upload; Lunar8Ops does not require special-category data and asks you not to upload it unless necessary.

3. Subprocessors

You authorise the subprocessors listed in our Privacy & Security Statement (§10). We impose data-protection obligations on each subprocessor no less protective than those in this DPA, and remain liable for their performance. We will give notice of a new subprocessor before it begins processing your data, and you may object on reasonable data-protection grounds.

4. Security

We apply database-level row security so one customer's data cannot be read while serving another, encrypt bring-your-own-key secrets with AES-256-GCM at rest, restrict production access, and never use your content to train any AI model. Full detail is in the Privacy & Security Statement.

5. International transfers

We host your database and file storage in an Australian region. AI inference occurs outside Australia (principally the United States) under commercial API terms that prohibit training on your content, as disclosed in the Privacy Statement (§5). If you require onshore-only processing, contact us before uploading regulated material.

What consenting to this means, stated plainly because the law requires us to state it. Where you consent to your content being disclosed to a processor outside Australia, Australian Privacy Principle 8.1 does not apply to that disclosure. In practice that means: if that overseas provider mishandles the information in a way that would breach the Australian Privacy Principles, we are not accountable for it under the Privacy Act, and you cannot seek a remedy for it under the Privacy Act. Your rights against us under our terms, the Australian Consumer Law and your contract are unaffected. We choose providers on commercial terms that prohibit training on your content and we tell you which countries are involved (currently the United States; and China if you select Moonshot or DeepSeek with your own key), but we cannot give you a Privacy Act remedy against a company we do not control. If that is not acceptable for the material you are handling, use your own API key or ask us about onshore-only processing before you upload it.

6. Assistance, breach & deletion

We assist you with data-subject requests and provide self-serve export and deletion in the product. We will notify you without undue delay after becoming aware of a personal data breach affecting your content. On termination, you may export everything, and your data is deleted on account deletion with residual backups purged within 30 days.

7. Countersigned copy

Procurement teams needing an executed copy on company letterhead can request one via the support address in your account. Using the Service constitutes acceptance of this DPA in the meantime.