Data processing terms
How we handle personal information on a client's behalf.
These terms are part of the master services agreement between a client and Iron Rod Systems LLC, a Utah limited liability company ("we", "us"). They apply wherever a client gives us personal information and data protection law makes the client its controller and us its processor. They take effect when the client signs the mutual non-disclosure agreement or the master services agreement, whichever comes first. Nothing more needs signing, and we will sign a counterpart if a client's process wants one.
1. Which information this covers
- Client information is what a client and its people give us for a discovery or for the work that follows: answers, recordings, transcripts, documents, screen recordings, and access to the client's systems and the data in them. The client decides what to give us and why. The client is the controller, we are its processor, and these terms govern.
- Our own records are who a client's people are and how to reach them, the agreements signed, and invoices. We decide how to handle those in order to run a business, so we are their controller and our privacy notice governs instead.
Where a term is defined in the GDPR, the UK GDPR or the CCPA, it carries that meaning here.
2. What we do with it, and why
We process client information only to carry out the discovery, to perform the work in a statement of work, to keep the portal and what we build secure and running, and to support the client when asked. We do not sell it, share it for advertising, use it to serve another client, use it to train models, or mine it for statistics.
3. The client's instructions
We process client information only on the client's documented instructions. The signed agreements, these terms, and what the client's people choose to share and ask of us are those instructions. We will tell the client if an instruction appears to break data protection law, and may pause that processing while it is sorted out. If a law we are subject to compels us to go beyond the instructions, we will tell the client first unless that law forbids it.
4. Who can see it
Access is limited to the people at Iron Rod Systems working on that client, each under a written duty of confidentiality that outlasts their time with us. Access within our team can be limited client by client, and administrative actions are logged in an audit trail.
5. Security
We keep the measures in Annex II, judged against the risk to the people the information is about. We may change a measure as the portal changes, but not in a way that materially weakens overall security. Our security page carries the working detail.
6. Subprocessors
The client gives us general authorization to use subprocessors. Those that may handle client information are named in Annex III. Each is bound by written terms no less protective than these, and we remain responsible to the client for what they do. Before adding or replacing one, we give at least 30 days' notice by email to the client's sponsor. If the client has a reasonable data protection objection and we cannot offer an alternative, the client may end the affected work and we refund fees prepaid for the unused part.
7. When someone asks about their information
People whose information a client gave us deal with the client, because the client is the controller. If one of them comes to us directly, we tell them to contact the client, and tell the client promptly. We will help the client answer, including by finding, correcting, exporting or deleting what we hold, without charge for reasonable help.
8. If there is a breach
If we become aware of a personal data breach affecting client information, we notify the client without undue delay, and aim to within 72 hours. The notice says what we know: what happened, the kinds and rough number of records, the likely consequences, what we are doing, and who to talk to. We send what we know first and add to it as we learn more. We do not notify regulators or the people affected on the client's behalf unless the client asks us to in writing.
9. Assessments
If the client needs to carry out a data protection impact assessment or consult a regulator about our processing, we will give the information reasonably needed.
10. Getting it back, and deletion
On written request we return or delete client information within 30 days. Without a request, voice and screen recordings are deleted 30 days after the work ends: when the project concludes, when a managed services agreement ends, or when a proposal is not accepted; the rest is kept until the client asks for it to be returned or deleted. Copies the law requires us to keep, and copies in routine backups until they roll off within 35 days, remain protected by these terms.
11. Showing our work
On written request, no more than once a year unless there has been a breach, we will answer a reasonable security questionnaire and provide the information needed to show we meet these terms. If that is not enough to meet a legal requirement, we will agree a proportionate audit, at the client's cost, on reasonable notice and without access to other clients' information.
12. Sending information across borders
We and our subprocessors process client information in the United States. Where client information comes from the EEA, the UK or Switzerland, the European Commission's standard contractual clauses (processor to controller and controller to processor modules, as the roles require), with the UK addendum where it applies, are incorporated into these terms, with the details in the annexes. If the clauses and these terms conflict, the clauses control.
13. California
For the CCPA we are a service provider. We do not sell or share client information, do not keep, use or disclose it outside our direct relationship with the client or for any purpose other than the services, and do not combine it with personal information from other sources except as the CCPA allows a service provider to. We will tell the client if we can no longer meet these obligations.
14. Regulated records
These terms do not make us a business associate under HIPAA or cover payment card data. We ask clients not to send such records. If a statement of work needs them, it must say so, and the further agreement the law requires must be signed first.
15. Precedence, liability and law
If these terms and the master services agreement conflict on the handling of personal information, these terms control. Liability under these terms is subject to the limits in the master services agreement. These terms are governed by the law that governs that agreement.
Annex I · The processing
Parties
The client (controller), and Iron Rod Systems LLC (processor), legal@discoverpro.ai.
Categories of people
The client's owners, employees and contractors who take part in a discovery. The client's own customers, suppliers and employees, to the extent they appear in documents, recordings or systems the client shares.
Categories of personal information
Names, job titles and work contact details. Voice recordings and what was said in them. Whatever personal information appears in documents, screen recordings and systems the client chooses to share, which we ask the client to keep to what is needed to describe the work.
Special category data
None is intended. We ask clients not to share it, the interviewer is instructed not to ask for it, and we delete it when we find it.
How often, and how long
Continuously during a discovery and any work that follows, and then as section 10 says.
Nature and purpose
Collecting, recording, transcribing, storing, analysing and summarising, in order to assess the client's processes, propose improvements, and build and run what the client agrees to.
Annex II · Technical and organizational measures
- Encryption in transit (HTTPS enforced, TLS 1.2 or newer) and at rest; a further layer of encryption for secrets our software holds.
- Personal links stored only as fingerprints, with a code sent to the person's own email on any new device.
- No passwords for our team: one-time sign-in to an approved address plus a required second step (passkey or authenticator app).
- Access by role and by client; least access needed for the work.
- A tamper-evident audit trail of administrative actions.
- Rate limiting on sign-in, codes and client requests; cross-site requests refused for anything that changes data.
- A strict browser content policy, and no third-party scripts on any signed-in page.
- Scheduled deletion of recordings; deletion of other material on request and at the end of the work.
- Instructions to the AI interviewer and to the write-up not to collect or repeat personal details that are not needed, with a person reviewing output before it is used.
- Written confidentiality duties for everyone with access.
Annex III · Subprocessors
- Cloudflare, Inc. (United States). Hosting, database, file storage, and sending email from the portal. Handles all client information held in the portal.
- ElevenLabs, Inc. (United States). The voice interviewer: speech recognition, speech, and the live conversation, and transcription of narrated recordings. Handles interview audio and transcripts, and holds interview audio until we delete it.
- Anthropic, PBC (United States). Claude models that write up interviews, read shared documents, and draft assessments, proposals and statements of work, and that power the interviewer through ElevenLabs. Handles the text of answers, transcripts and documents.
Providers we use only for our own outreach, such as our mailbox host and business-contact providers, do not receive client information and are described in our privacy notice.