Data processing addendum

Version celrow-dpa-2026-10-23. Approved 2026-10-23. This addendum applies where Celrow processes personal data on a customer's behalf, regardless of plan. It is not a certification that every regional or transfer requirement has already been completed.

Celrow is a trading name of Seymour Industrial (Shanghai) Co., Ltd., the service operator (operator details). Contact [email protected] for processing instructions, rights requests and audits.

Roles and instructions

The customer determines the lawful purposes and means for personal data in uploaded business emails, attachments and requested results, and is the controller or the authorized processor of its own customer. Celrow acts as processor or sub-processor for that document processing, only on documented instructions in the service agreement and authorized requests, unless legally required otherwise. Celrow remains responsible as a controller for its account, billing and security administration described in the privacy notice. We will inform the customer if an instruction appears to breach applicable data-protection law.

Scope and duration

Processing consists of receiving, extracting, structuring, translating or drafting at the customer's request, temporarily storing results, and deleting them. Data subjects may include the customer's employees, business contacts, suppliers and customers. Data may include names, business contact details and business order or invoice content. Do not submit special-category or criminal-offence data unless expressly agreed and lawful. Processing lasts for the requested task and applicable service-retention period; original buffers and results follow the short periods in the privacy notice. Legal financial records are separate from customer document contents.

Confidentiality and security

Personnel with access must be authorized, bound by confidentiality and limited to the necessary purpose. Celrow applies the documented technical and organizational measures in its security notice, including transport protection, access control, short retention and restricted recovery. Restored data must respect later deletions before service resumes. We do not use customer document data for advertising or to train our own models.

Sub-processors and locations

The service providers, functions and known locations are described in the privacy notice. We engage sub-processors under data-protection obligations appropriate to their role and remain responsible for their performance of the processing obligations owed to the customer. We will give advance notice of material additions or replacements and a reasonable opportunity to raise a substantiated data-protection objection; contact support to resolve the objection before affected processing continues. A supplier's own independent-controller activities follow its own notice. No statement here represents an uncompleted supplier agreement as executed.

Requests, incidents and assistance

Taking account of the nature of processing and information available, Celrow assists with lawful data-subject requests, security duties, impact assessments and regulator consultations. We notify the customer without undue delay after becoming aware of a personal-data breach affecting its data, share available relevant information, and cooperate on mitigation and required notices. We do not require an upgrade to receive legally required assistance.

Return, deletion and audits

At the end of covered processing, the customer may export available results within the service's retention window. Celrow deletes or returns covered personal data as instructed, except for a legal retention obligation, which must be identified and access restricted. Restricted backups expire under the approved policy and cannot be restored for ordinary use without reapplying subsequent deletions. Celrow makes information necessary to demonstrate these obligations available and permits proportionate audits or inspections by the customer or its independent auditor under reasonable confidentiality and security arrangements. These arrangements cannot prevent a legally required audit.

International processing

Actual hosting, supplier processing and authorized access determine locations; a US hosting location does not promise US-only access. Where a transfer requires additional safeguards, approved transfer instruments and any required representative arrangements must be completed before the affected processing begins. These terms do not themselves appoint a representative, execute a supplier agreement or complete a transfer assessment. Mandatory data-protection rights prevail over inconsistent service terms.