Data Processing Agreement

Last updated: 13 August 2026

Operator

Charlotte Chartrou, Individual founder — sole operator.

1. Roles

When you use Pionyra to process data about your company, prospects, customers, team or contacts, you normally act as controller. Pionyra acts as processor for processing performed on your documented instructions.

2. Subject and duration

We process data to provide the platform: AI-assisted content, supervised workflows, integrations, messaging, performance analysis, support and security. Processing lasts for the subscription period and the retention periods described in the Privacy Policy.

3. Data categories

Data may include account information, company profile data, prompts, content, uploaded files, conversations, drafts, publications, metrics, inbox messages, connected-account identifiers and technical logs.

4. Customer instructions

Your instructions are expressed through workspace configuration, prompts, approvals, integrations, support requests and dashboard settings. We may refuse or suspend an instruction that appears unlawful, excessive or incompatible with a third-party platform rule.

5. Sub-processors

Sub-processors are listed in the Privacy Policy. They cover hosting, database, payments, email, AI, monitoring and connected platforms. Access is limited to what each provider needs.

6. International transfers

Some providers may process data outside the UAE, including in the United States or other jurisdictions where they operate. Transfers are limited to service needs and protected by appropriate safeguards when required.

7. Security

We use reasonable technical and organisational measures including encryption in transit, encrypted access tokens, account-level data isolation, access controls, backups and technical logging.

8. Data-subject requests

We reasonably assist you with access, correction, deletion, restriction, objection or portability requests relating to data processed on your behalf.

9. Security incidents

If a confirmed incident affects personal data processed for your account, we notify you within a reasonable time with available details, measures taken and useful recommendations.

10. End of service

At the end of the service, we delete or return data according to available features, your instructions and applicable legal retention duties.