Elena BridgeData Processing Agreement
1. Parties and scope
This agreement is between the customer (controller) and La Lumière Consulting BV (processor). It is part of the terms and is accepted with them at sign-up. It covers the personal data in the customer's Elena Bridge workspace.
2. The processing
| Subject and purpose | Storing, syncing and showing the customer's communications work: who is waiting, drafts, people, deals, meetings and todos, for the customer's members |
|---|---|
| Duration | The subscription, then the return and deletion periods in section 9 |
| Data subjects | The customer's members and guests; the people they write to and meet |
| Personal data | Names, email addresses, phone numbers, LinkedIn and Telegram handles, photos, message text and metadata, calendar events, meeting summaries, notes, deal details |
| Special categories | Not intended. They may appear in message text the customer connects |
3. Instructions
We process the data only on the customer's documented instructions: these terms, this agreement and the customer's use of the service. We tell the customer if an instruction seems to break data protection law.
4. Confidentiality
Everyone at La Lumière with access is bound to confidentiality. Access to customer content is limited to what a support request the customer makes, a security incident or the law requires, and is logged.
5. Security
We apply the measures in the annex below and keep them current.
6. Sub-processors
- The customer authorises the sub-processors on sub-processors.
- We announce a new one at least 30 days ahead. The customer may object on reasonable grounds; if we can't resolve it, the customer may end the affected plan with a refund of the unused part.
- Each sub-processor is bound to the same data protection duties as we are.
7. The customer's own providers
Elena runs in the customer's own Claude Code under each member's contract with Anthropic. Anthropic, and the channels the customer connects (Google, LinkedIn, WhatsApp, Telegram), are chosen by the customer and are not our sub-processors. Elena Bridge never sends data to Anthropic. We recommend members turn off Claude's "Help improve Claude" setting for business data, and that teams use Claude Team.
8. Assistance
- We help the customer answer data subject requests, mostly through export and deletion in the app.
- We help with impact assessments and prior consultations, with the information we hold.
- We notify the customer of a personal data breach without undue delay, with a target of 48 hours after we become aware, and with what we know then.
9. Return and deletion
The customer can export the whole workspace at any time. After the subscription ends, the data stays retrievable for 30 days and is then deleted, backups included within [backup retention], unless law requires us to keep it.
10. Audits
We make available the information needed to show compliance with this agreement. Audits run on documentation first. An on-site audit needs 30 days' notice, happens in business hours, at the customer's cost, at most once a year.
11. Transfers
The workspace is hosted in the EU. A transfer outside the EEA happens only through a sub-processor listed with its safeguard.
Annex · security measures
- Hosting on Fly.io in an EU region. Volumes encrypted at rest. TLS on every connection.
- Every query is scoped to one workspace, and an automated test proves no route returns another workspace's rows.
- Private by default: a member's threads, messages and drafts are visible to that member only until shared. Admins can't read members' private threads.
- Sign-in by single-use email link. Sessions in HttpOnly cookies. API tokens stored as hashes and shown once.
- No message text in logs, error reports or support tickets.
- Sending only on a member's press, and only the exact text pressed, checked by hash.
- Audit log of sharing, merges, exports and member changes.
- Backups: [backup schedule, location, restore test].