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1. Parties and scope
This Data Processing Addendum (“DPA”) forms part of the Notesix Terms of Service or another agreement between the Customer and Nsix Digital Sàrl (“Notesix”). It applies when Notesix processes Customer Personal Data to provide the Service.
The Customer is the controller or processor that lawfully appoints Notesix. Notesix is the processor or subprocessor. Terms such as personal data, processing, controller, processor and data subject have the meanings given by the Swiss Federal Act on Data Protection (“FADP”) and, where applicable, the EU or UK GDPR.
2. Customer instructions and responsibilities
Notesix processes Customer Personal Data only on the Customer’s documented instructions, including the Terms, workspace configuration, integrations and support requests, unless applicable law requires otherwise. Notesix will inform the Customer before legally required processing unless prohibited.
The Customer determines whether, why and how meetings and connected records are processed. The Customer must have a valid legal basis, give required notices, obtain required consents and permissions, respect recording and employment laws, configure appropriate access, and avoid submitting unlawful or unnecessary data.
If Notesix reasonably believes an instruction violates applicable data-protection law, it may suspend that instruction and notify the Customer.
3. Processing details
- Subject and purpose: browser-based meeting capture, transcription, structured notes, workflow automation, selected integrations, support, security and service administration.
- Duration: the Customer’s subscription plus the deletion and backup periods described below.
- Data subjects: Customer users, meeting participants, contacts in connected systems, support contacts and other persons whose data the Customer submits.
- Data: identity and account details, meeting audio and transcripts, generated notes and actions, meeting metadata, selected CRM or integration records, identifiers, configuration, support communications, audit and technical data.
- Special data: Notesix does not require sensitive data. If the Customer chooses to submit it, the Customer is responsible for an appropriate legal basis and safeguards.
- Operations: collection, transmission, organisation, storage, analysis, generation, retrieval, consultation, synchronisation, restriction and deletion.
4. Confidentiality and personnel
Notesix limits access to authorised personnel who need it to operate, secure or support the Service. Those persons are bound by confidentiality obligations and receive appropriate privacy and security instructions. Notesix remains responsible for their compliance with this DPA.
5. Security measures
Notesix maintains risk-appropriate technical and organisational measures, including encrypted transport, authenticated sessions, role-based access and workspace isolation, least-privilege administration, encrypted integration credentials, signed webhook verification, audit and security logging, backup controls, vendor review, incident response and processes for deletion and recovery.
Measures evolve with risk and technology. Notesix may replace a measure with an equivalent or stronger safeguard without materially reducing overall security. The Customer is responsible for its endpoints, credentials, user permissions, connected tools and secure configuration.
6. Subprocessors
The Customer gives general written authorisation for the subprocessors listed on the Subprocessor page. Notesix contractually requires them to protect personal data to a substantially equivalent standard and remains responsible for their processing as required by law.
Notesix will announce a new subprocessor at least 30 days before it begins materially processing Customer Personal Data. The Customer may object during that period on reasonable data-protection grounds. The parties will seek a practical solution; if none exists, the Customer may terminate the affected Service before the change takes effect.
7. International transfers
Notesix may process data in Switzerland, the EEA and other locations used by authorised providers. Transfers rely on an adequacy decision where available, including recognised Switzerland–EEA transfers. Otherwise Notesix uses an applicable transfer mechanism, such as the European Commission Standard Contractual Clauses with the Swiss or UK adaptations when required, plus supplementary safeguards where appropriate.
For restricted EEA transfers where Notesix is a processor, the controller-to-processor modules of the EU Standard Contractual Clauses are incorporated by reference. The Customer is the data exporter, Notesix is the data importer, the details in this DPA complete the annexes, optional docking applies, and the competent authority and governing law are determined by the exporter’s establishment or otherwise Ireland.
8. Assistance and data-subject requests
Taking into account the processing and information available, Notesix assists the Customer with data-subject requests, security obligations, breach notifications, impact assessments and prior consultations. If Notesix receives a request relating to Customer-controlled data, it will direct the requester to the Customer unless legally required to respond, and will reasonably assist the Customer.
Ordinary assistance through Service features is included. Notesix may charge reasonable costs for exceptional, repetitive or bespoke assistance after giving notice, unless the assistance is required because Notesix breached this DPA.
9. Security incidents
Notesix will notify the Customer without undue delay after confirming a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Customer Personal Data. Notice will include available information reasonably needed for the Customer’s obligations, and Notesix will investigate, mitigate and provide updates. Notification is not an admission of fault.
10. Review and audit
Notesix will provide information reasonably necessary to demonstrate compliance. No more than once annually, unless required by a regulator or following a substantiated incident, the Customer may request relevant independent reports or conduct an audit through a qualified independent auditor. Audits require reasonable notice, must protect other customers and security, avoid disruption, and are at the Customer’s cost unless a material Notesix breach is found.
11. Return and deletion
During the subscription, Customer features may be used to export available data. After account closure, active Customer Content is deleted or anonymised within 30 days unless law requires retention. Residual encrypted backups expire within 90 days. Technical, security and audit logs may be kept for up to 12 months, and billing or legal records for the statutory period. Data isolated in backups is not restored except for disaster recovery and remains protected until deletion.
12. Liability, precedence and termination
The liability limitations in the Terms or main agreement apply to this DPA to the extent permitted by mandatory law. If documents conflict on personal-data processing, this DPA prevails, followed by applicable transfer clauses, then the main agreement. This DPA lasts while Notesix processes Customer Personal Data.
13. Contact
Privacy and DPA questions: Nsix Digital Sàrl, Panoramastrasse 26, 8903 Birmensdorf ZH, Switzerland · contact@nsixdigital.com.