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GDPR & data processing agreement (DPA)

Admin

⚖️ Not legal advice. Plain-language summary; what is binding are evanto’s legal documents (DPA, privacy policy, License terms).

Who is responsible under data protection law for the data processed in CompanyWizard depends on the operating model. The decisive factor is whether you run it self-hosted or have evanto run your Site instance in Managed operation. Independently of that, the Managed AI add-on makes evanto a processor for model access.

Two constellations: self-hosted (customer = controller, evanto not a processor) and Managed operation (DPA under Art. 28 for the instance evanto operates). Two constellations: self-hosted (customer = controller, evanto not a processor) and Managed operation (DPA under Art. 28 for the instance evanto operates).

Self-hosted (Free, Pro, Site without Managed operation)

Section titled “Self-hosted (Free, Pro, Site without Managed operation)”

You run the application in your own environment. You are the controller for all content you enter; evanto has no access to it and is not a processor. evanto processes only its own license data (as its own controller). AI model providers you connect (bring your own key) are your responsibility.

Exception Managed AI: if you book the Managed AI add-on, evanto provides the model access and is a processor for that processing; the DPA applies in addition. For this, evanto engages the aggregator Cortecs GmbH (Vienna) as a sub-processor. → Managed AI: what it covers

In Managed operation, evanto operates your Site instance dedicated per customer, from tier L additionally with its own vector database (Qdrant) and PII detection (Presidio). For this processing, evanto is a processor; a data processing agreement (DPA) under Art. 28 GDPR additionally applies. Operation takes place exclusively in the EU/EEA (R-KOM data center, Regensburg); subprocessors are disclosed there. → Data sovereignty · License & edition model

AspectSelf-hostedManaged operation
ControllerYouYou
evanto rolenot a processorprocessor (DPA)
evanto access to contentnodedicated, instruction-bound
Hostingyour environmentEU/EEA (R-KOM)
BYO model providersyour responsibilityyour responsibility
Managed AIevanto processor for model access (DPA)evanto processor for model access (DPA)
  • In both cases, you remain responsible for the legal basis, data subject rights and, where applicable, a data protection impact assessment.