Data Processing Agreement (DPA)
Effective Date: February 11, 2026
This Data Processing Agreement ("DPA") forms part of the agreement between aiMiles, Inc. ("Processor") and the customer identified in the applicable order form or agreement ("Controller") and governs the processing of Personal Data in accordance with applicable data protection laws.
Terms such as Personal Data, Processing, Controller, and Processor have the meanings given to them under the EU General Data Protection Regulation ("GDPR") and other applicable data protection laws.
1. Definitions
Terms such as Personal Data, Processing, Controller, and Processor have the meanings given to them under the EU GDPR and other applicable data protection laws.
These terms ensure clarity in the rights and responsibilities under this DPA.
2. Scope and Purpose of Processing
Processor processes Personal Data on behalf of Controller solely to provide aiMiles' services, which include detecting automated agent traffic, classifying requests, and dynamically inserting text-based sponsored content into HTML responses prior to delivery.
Processing is limited to what is necessary to identify AI or automated agents, serve contextual sponsored content, and generate aggregated analytics.
3. Nature and Categories of Data
Nature of Processing: Automated detection, classification, modification, and logging of HTTP requests and responses.
Categories of Personal Data: Transient IP addresses (processed in-memory only and not stored or retained), user-agent strings, and request metadata. Processor does not intentionally process special categories of Personal Data.
4. Obligations of the Processor
Processor shall only process Personal Data on documented instructions from Controller and ensure persons authorized to process Personal Data are bound by confidentiality.
Processor must implement appropriate security measures and not sell or independently exploit Personal Data.
5. Subprocessors
Controller authorizes the use of subprocessors necessary to provide services. Processor is responsible for subprocessors' compliance with this DPA.
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Processor will provide notice of material subprocessor changes upon request.
6. Data Security
Processor implements industry-standard administrative, technical, and physical safeguards to protect Personal Data.
These measures aim to prevent accidental or unlawful loss, destruction, alteration, unauthorized disclosure, or access.
7. International Transfers
Where Personal Data is transferred outside the EEA, appropriate safeguards are implemented including Standard Contractual Clauses.
Processor ensures such transfers comply with applicable data protection laws.
8. Assistance and Data Subject Rights
Processor provides reasonable assistance to Controller in responding to data subject requests and regulatory inquiries.
Assistance is provided to the extent required by law and as related to Processor's services.
9. Deletion and Return of Data
Upon termination, Processor will delete or return Personal Data according to applicable law, unless retention is legally required.
This ensures the Controller's data rights are respected at the end of service.
10. Liability
Each party's liability under this DPA is subject to limits stated in the main agreement.
This ensures alignment with the overall contractual obligations.
11. Governing Law
This DPA is governed by the same law as the main agreement between the parties.
Applicable laws will provide the framework for resolving any disputes under this DPA.