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Data Processing Agreement

Legal Document Last updated: October 3, 2025

KData Processing Agreement (DPA) for Kapturo

Last updated: October 3, 2025

This Data Processing Agreement ("DPA") is between Coffee Tap Studio SRL (trading as Kapturo), a company registered in Romania with company number 49753478, and you, the customer ("you", "user"). This DPA forms part of our Terms of Service and explains how we process your data on your behalf.

1. Key Terms (Plain English)

  • Controller – That's you. You decide what content to capture and what social media posts to generate.
  • Processor – That's us, Kapturo. We process your captured content only to provide you with the Kapturo service.
  • Subprocessor – These are the trusted vendors we use to help run the Kapturo service, such as hosting providers and AI model providers.

2. Scope of Processing

  • What we process: We process the content you capture with the Kapturo native applications (including screen captures, text, and other data), your inputs into our conversational interface, and the social media posts you generate. We also process standard account information like your email address.
  • How we process it: We store your content and process it to allow you to manage it and generate new content (social media posts) through our web portal. We process data only based on your instructions and actions within the Kapturo apps and web portal.
  • Purpose: The sole purpose of processing is to provide, maintain, and improve the Kapturo service. We will never sell your data or use it for our own marketing or advertising purposes.

3. Use of Third-Party AI Tools

Kapturo utilizes third-party AI models (Large Language Models or LLMs) to power its conversational content generation features. To provide this service, the content you select and your instructions will be sent to our AI Subprocessors for processing. By using Kapturo, you acknowledge and explicitly consent to your data being processed by these third-party services for this purpose.

4. Data Retention

  • Account Data: We retain your account information as long as your account is active. It is deleted upon account termination.
  • User Content: Your captured content and generated posts are retained to provide you with the service and are available for you to manage and delete through the web portal. If you delete content, it is permanently removed from our active systems. Data may persist in secure backups for a limited period before being permanently deleted.

5. Subprocessors

We use a limited number of trusted vendors to provide our service. Our current Subprocessors are:

  • Microsoft Azure (for hosting and Azure OpenAI services)
  • DigitalOcean (for hosting)

We may add or change Subprocessors in the future. We will update this DPA to reflect any changes.

6. International Data Transfers

Our service infrastructure is hosted by global providers. This means your data may be stored and processed in data centers located outside of your country of residence, including outside the European Union/EEA. We rely on the security and legal frameworks of our Subprocessors (such as Standard Contractual Clauses) to ensure that any international data transfers comply with applicable data protection laws.

7. Security Measures

We implement the following security measures to protect your data:

  • Encryption: All data is encrypted in transit using industry-standard HTTPS/TLS.
  • Access Control: Your account is secured by your login credentials. You are the only one who can access your captured content.
  • Secure Infrastructure: We use reputable, secure, and established vendors for all our hosting and processing needs.

8. Beta Service & Warranty

Kapturo is currently provided as a "beta" service. The service is provided "as is" and without any warranties. We do not guarantee that the service will be error-free or uninterrupted.

9. Roles & Responsibilities

Your Responsibilities:

  • You are responsible for the legality of the content you capture and process with Kapturo.
  • You are responsible for complying with all applicable laws and regulations regarding the content you generate and publish.
  • You must maintain the confidentiality of your account credentials.

Our Responsibilities:

  • We will process your data only in accordance with your instructions and this DPA.
  • We will maintain the security and confidentiality of your data.
  • We will assist you, within reason, in meeting your data protection obligations.

10. Governing Law

This DPA is governed by the laws of Romania. Any disputes arising from this DPA will be resolved exclusively in the courts of Romania.

By using Kapturo, you agree to the terms of this Data Processing Agreement.

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