Data Processing Agreement

Name: Robin AI
Price range: $

PARTIES

Robin AI Limited incorporated and registered in England and Wales with company number 1400135 (“Supplier”)
The entity or individual accessing or using the Robin AI platform, as identified in the user account, Order Form, Service Agreement, or other agreement between the parties ("Customer")

BACKGROUND

The Customer has either entered into an agreement with the Supplier (the "Service Agreement") and/or has accessed or used the Supplier's platform or services, which may require the Supplier to process Personal Data on behalf of the Customer. This Data Processing Agreement applies to and governs all Personal Data processing activities conducted by the Supplier on behalf of the Customer, regardless of whether a formal Service Agreement exists or the form such agreement may take (including but not limited to subscription agreements, order forms, terms of service, or other commercial agreements).
This Data Processing Agreement (Agreement) sets out the terms, requirements and conditions on which the Supplier will process Data when providing services under the Services Agreement. This Agreement contains the mandatory clauses required by Article 28(3) of the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) for contracts between controllers and processors and the General Data Protection Regulation ((EU) 2016/679).
This Agreement applies to individuals or entities who access or use the Robin AI platform under a free trial offering (“Free Trial Users”), without entering into a paid Services Agreement. By registering for, accessing, or using the platform during the free trial period, the Free Trial User acknowledges and agrees to be bound by the terms of this Data Processing Agreement, solely to the extent that Robin AI processes Personal Data on their behalf during the trial.

AGREED TERMS

Definitions and interpretation

The following definitions and rules of interpretation apply in this Agreement.

Definitions:
Authorised Persons: the individuals who are authorized to give the Supplier written personal data processing instructions on behalf of the Customer, which may include the Customer's account administrators, designated data protection officers, legal representatives, or other personnel with appropriate authority as designated through the Supplier's platform or in writing to the Supplier.
Business Purposes: the services to be provided by the Supplier to the Customer as described in the Service Agreement, through the Supplier's platform, or as otherwise agreed between the parties, including any specific purposes identified in ANNEX A.
Commissioner: the Information Commissioner (see Article 4(A3), UK GDPR and section 114, DPA 2018).
Controller: has the meaning given to it in section 6, DPA 2018, and/or “controller,” “business” or like term as defined by applicable Data Protection Legislation.
Data Protection Legislation:
1. To the extent the UK GDPR applies, the law of the United Kingdom or of a part of the United Kingdom which relates to the protection of Personal Data.
2. To the extent the EU GDPR applies, the law of the European Union or any member state of the European Union to which the Customer or Supplier is subject, which relates to the protection of Personal Data.
3. any other laws, regulations, or orders regulating the collection, use, disclosure, storage, transfer, privacy, security or other Processing of Personal Data including, without limitation, the California Consumer Privacy Act (“CCPA”)
Data Subject: the identified or identifiable living individual to whom the Personal Data relates.
EU GDPR: the General Data Protection Regulation ((EU) 2016/679).
EEA: the European Economic Area.
Personal Data: means any information relating to an identified or identifiable living individual that is processed by the Supplier on behalf of the Customer as a result of, or in connection with, the provision of the services under the Services Agreement; an identifiable living individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, prompting, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.
Processing, processes, processed, process: any activity that involves the use of the Personal Data. It includes, but is not limited to, any operation or set of operations which is performed on the Personal Data or on sets of the Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Processing also includes transferring the Personal Data to third parties.
Personal Data Breach: a breach of security leading to the accidental, unauthorised or unlawful destruction, loss, alteration, disclosure of, or access to, the Personal Data.
Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller, and/or “processor,” “service provider” or a like term as defined by applicable Data Protection Legislation.
Records: has the meaning given to it in Clause 12.
Standard Contractual Clauses (SCCs): the ICO's International Data Transfer Agreement for the transfer of personal data from the UK and/or the ICO's International Data Transfer Addendum to EU Commission Standard Contractual Clauses and/or the European Commission's Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 as set out in the Annex to Commission Implementing Decision (EU) 2021/914 and/or the European Commission's Standard Contractual Clauses for the transfer of Personal Data from the European Union to processors established in third countries (controller-to-processor transfers), as set out in the Annex to Commission Decision 2010/87/EU as adapted for the UK, as amended from time to time, are hereby incorporated by reference into this Agreement in their entirety.
Term: this Agreement's term as defined in Clause 10.
UK GDPR: has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the DPA 2018.
1. This Agreement is subject to the terms of any Service Agreement between the parties and is incorporated into such Service Agreement where one exists. Where applicable, interpretations and defined terms set forth in the Service Agreement apply to the interpretation of this Agreement. In the absence of a formal Service Agreement, this Agreement stands as an independent agreement governing the processing of Personal Data in connection with Customer's use of the Supplier's platform or services.
2. The Annexes form part of this Agreement and will have effect as if set out in full in the body of this Agreement. Any reference to this Agreement includes the Annexes.
3. A reference to writing or written includes email.
4. In the case of conflict or ambiguity between:
  1. any provision contained in the body of this Agreement and any provision contained in the Annexes, the provision in the body of this Agreement will prevail;
  2. the terms of any accompanying invoice or other documents annexed to this Agreement and any provision contained in the Annexes, the provision contained in the Annexes will prevail;
  3. any of the provisions of this Agreement and the provisions of the Services Agreement, the provisions of this Agreement will prevail; and
  4. any of the provisions of this Agreement and any executed SCC, the provisions of the executed SCC will prevail.
Personal data types and processing purposes
1. The Customer and the Supplier agree and acknowledge that for the purpose of the Data Protection Legislation:
  1. the Customer is the Controller and the Supplier is the Processor, except where Customer is a Processor and Supplier is a sub-Processor.
  2. the Customer retains control of the Personal Data and remains responsible for its compliance obligations under the applicable Data Protection Legislation, including but not limited to providing any required notices and obtaining any required consents, and for the written processing instructions it gives to the Supplier.
  3. ANNEX A describes the subject matter, duration, nature and purpose of the processing and the Personal Data categories and Data Subject types in respect of which the Supplier may process the Personal Data to fulfil the Business Purposes.
Supplier's obligations
1. The Supplier will only process the Personal Data to the extent, and in such a manner, as is necessary for the Business Purposes in accordance with the Customer's written instructions from Authorised Persons. The Supplier will not process the Personal Data for any other purpose or in a way that does not comply with this Agreement or the Data Protection Legislation or outside of the direct business relationship between the parties. For avoidance of doubt, Supplier shall not “sell” or “share” Personal Data, as those terms are defined by applicable Data Protection Legislation. The Supplier must promptly notify the Customer if, in its opinion, the Customer's instructions do not comply with the Data Protection Legislation or if Supplier makes a determination that it can no longer meet its obligations under this Agreement or applicable Data Protection Legislation.
2. The Supplier must comply promptly with any Customer written instructions from Authorised Persons requiring the Supplier to amend, transfer, delete or otherwise process the Personal Data, or to stop, mitigate or remedy any unauthorised processing.
3. The Supplier will maintain the confidentiality of the Personal Data and will not disclose the Personal Data to third parties unless the Customer or this Agreement specifically authorises the disclosure, or as required by domestic law, court or regulator (including the Commissioner). If a domestic law, court or regulator (including the Commissioner) requires the Supplier to process or disclose the Personal Data to a third party, the Supplier must first inform the Customer of such legal or regulatory requirement and give the Customer an opportunity to object or challenge the requirement, unless the domestic law prohibits the giving of such notice.
4. The Supplier will reasonably assist the Customer, at no additional cost to the Customer, with meeting the Customer's compliance obligations under the Data Protection Legislation, taking into account the nature of the Supplier's processing and the information available to the Supplier, including in relation to Data Subject rights, data protection impact assessments and reporting to and consulting with the Commissioner or other relevant regulator under the Data Protection Legislation. Customer may take reasonable and appropriate steps to help ensure that Supplier Processes Personal Data in a manner consistent with Customer’s obligations under Data Protection Legislation, and to stop and remediate unauthorized use of Personal Data.
5. The Supplier must promptly notify the Customer of any changes to the Data Protection Legislation that may reasonably be interpreted as adversely affecting the Supplier's performance of the Services Agreement or this Agreement.
Supplier's employees
1. The Supplier will ensure that all of its employees:
  1. are informed of the confidential nature of the Personal Data and are bound by confidentiality obligations and use restrictions in respect of the Personal Data;
  2. have undertaken training on the Data Protection Legislation relating to handling Personal Data and how it applies to their particular duties; and
  3. are aware both of the Supplier's duties and their personal duties and obligations under the Data Protection Legislation and this Agreement.
2. The Supplier will take reasonable steps to ensure the reliability, integrity and trustworthiness of and conduct background checks consistent with applicable domestic law on all the Supplier's employees with access to the Personal Data.
Security
1. The Supplier must at all times implement appropriate technical and organisational measures against unauthorised or unlawful processing, access, copying, modification, reproduction, display or distribution of the Personal Data, and against accidental or unlawful loss, destruction, alteration, disclosure or damage of Personal Data including, but not limited to, the security measures set out in ANNEX B.
2. The Supplier must implement such measures to ensure a level of security appropriate to the risk involved, including as appropriate:
  1. the pseudonymisation and encryption of personal data;
  2. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  3. the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and
  4. a process for regularly testing, assessing and evaluating the effectiveness of the security measures.
Personal Data Breach
1. The Supplier will as soon as reasonably possible and, in any event, within 72 hours notify the Customer if it becomes aware of:
  1. the loss, unintended destruction or damage, corruption, or unusability of part or all of the Customer Data. The Supplier will restore such Customer Data at its own expense as soon as possible.
  2. any accidental, unauthorised or unlawful processing of the Customer Data; or
  3. any Personal Data Breach.
2. Where the Supplier becomes aware of (a), (b) and/or (c) above, it shall, without undue delay, also provide the Customer with the following information:
  1. description of the nature of (a), (b) and/or (c), including the categories of in-scope Personal Data and approximate number of both Data Subjects and the Personal Data records concerned;
  2. the likely consequences; and
  3. a description of the measures taken or proposed to be taken to address (a), (b) and/or (c), including measures to mitigate its possible adverse effects.
3. Immediately following any accidental, unauthorised or unlawful Customer Data Processing or Personal Data Breach, the Supplier will reasonably co-operate with the Customer at no additional cost to the Customer, in the Customer's handling of the matter, including but not limited to:
  1. assisting with any investigation;
  2. providing the Customer with physical access to any facilities and operations affected;
  3. facilitating interviews with the Supplier's employees, former employees and others involved in the matter including, but not limited to, its officers and directors;
  4. making available all relevant records, logs, files, data reporting and other materials required to comply with all Data Protection Legislation or as otherwise reasonably required by the Customer; and
  5. taking reasonable and prompt steps to mitigate the effects and to minimise any damage resulting from the Personal Data Breach or accidental, unauthorised or unlawful Personal Data processing.
4. The Supplier will not inform any third party of any accidental, unauthorised or unlawful Processing of all or part of the Customer Data and/or a Personal Data Breach without first obtaining the Customer's written consent, except when required to do so by domestic law. Notwithstanding, Supplier may inform relevant regulatory authorities or affected individuals of a Personal Data Breach where required by applicable Data Protection Legislation.
5. The Supplier will cover all reasonable expenses associated with the performance of the obligations under clause ‎6.1 to clause ‎6.3 unless the matter arose from the Customer's specific written instructions, negligence, wilful default or breach of this Agreement, in which case the Customer will cover all reasonable expenses.
6. The Supplier will also reimburse the Customer for actual reasonable expenses that the Customer incurs when responding to an incident of accidental, unauthorised or unlawful processing and/or a Personal Data Breach to the extent that the Supplier caused such, including all costs of notice and any remedy as required by applicable Data Protection Legislation..
Cross-border transfers of personal data
1. The Supplier shall not transfer or otherwise process Personal Data outside the EEA unless such transfer is necessary for the performance of the Services and is carried out in compliance with applicable data protection laws. The Customer acknowledges that certain processing activities, such as interactions with large language models (LLMs), which may require data to be transferred to jurisdictions where such models are hosted or operated. Accordingly, the Supplier is permitted to transfer and/or process Personal Data on behalf of the Customer in the following jurisdictions: USA, UK, Singapore, South Africa, Australia, and Germany, and in any other jurisdiction where such processing is necessary to support the functionality or performance of the Services, provided that appropriate safeguards are in place in accordance with applicable data protection legislation.
2. Where such consent is granted, the Supplier may only process, or permit the processing, of the Personal Data outside the EEA under the following conditions:
  1. the Supplier is processing the Personal Data in a territory which is subject to adequacy regulations under the Data Protection Legislation that the territory provides adequate protection for the privacy rights of individuals. The Supplier must identify in ANNEX A the territory that is subject to such adequacy regulations; or
  2. the Supplier participates in a valid cross-border transfer mechanism under the Data Protection Legislation, so that the Supplier (and, where appropriate, the Customer) can ensure that appropriate safeguards are in place to ensure an adequate level of protection with respect to the privacy rights of individuals as required by Article 46 of the UK GDPR and EU GDPR. The Supplier must identify in ANNEX A the transfer mechanism that enables the parties to comply with these cross-border data transfer provisions and the Supplier must immediately inform the Customer of any change to that status; or
  3. the transfer otherwise complies with the Data Protection Legislation for the reasons set out in ANNEX A.
3. If any Personal Data transfer between the Customer and the Supplier requires execution of SCCs in order to comply with the Data Protection Legislation (where the Customer is the entity exporting Personal Data to the Supplier outside the EEA), the parties will complete all relevant details in, and execute, the SCCs which have been incorporated by reference into this Agreement and take all other actions required to legitimise the transfer.
4. If the Customer consents to appointment by the Supplier of a subcontractor located outside the EEA in compliance with the provisions of clause 8, then the Customer authorises the Supplier to enter into SCCs, which have been incorporated by reference into this Agreement, B with the subcontractor. The Supplier will make the executed SCCs available to the Customer on request.
Subcontractors
8.1 The Supplier may only authorise a third party (subcontractor) to process the Personal Data if:
1. the Supplier provides notice to the Customer regarding the appointment of each subcontractor by updating the list of subprocessors on its website or through other appropriate communication channels, and the Customer may object to such appointment in accordance with the process set forth in the Service Agreement or as otherwise communicated by the Supplier;
  1. the Supplier enters into a written contract with the subcontractor that contains terms substantially the same as those set out in this Agreement, in particular, in relation to requiring appropriate technical and organisational data security measures, and, upon the Customer's written request, provides the Customer with copies of the relevant excerpts from such contracts;
  2. the Supplier maintains control over all of the Personal Data it entrusts to the subcontractor; and
2. Those subcontractors approved as at the commencement of this Agreement are as set out in ANNEX A. The Supplier must list all approved subcontractors in Annex A and include any subcontractor's name and location and the contact information for the person responsible for privacy and data protection compliance.
3. Where the subcontractor fails to fulfil its obligations under the written agreement with the Supplier which contains terms substantially the same as those set out in this Agreement, the Supplier remains fully liable to the Customer for the subcontractor's performance of its agreement obligations.
4. The Parties agree that the Supplier will be deemed to control legally any Personal Data controlled practically by or in the possession of its subcontractors.
Complaints, data subject requests and third-party rights
1. The Supplier must, at no additional cost to the Customer, take such technical and organisational measures as may be appropriate, and promptly provide such information to the Customer as the Customer may reasonably require, to enable the Customer to comply with:
  1. the rights of Data Subjects under the Data Protection Legislation, including subject access rights, the rights to rectify, port and erase personal data, object to the processing and automated processing of personal data, and restrict the processing of personal data; and
  2. information or assessment notices served on the Customer by the Commissioner or other relevant regulator under the Data Protection Legislation.
2. The Supplier must notify the Customer immediately in writing if it receives any complaint, notice or communication that relates directly or indirectly to the processing of the Personal Data or to either party's compliance with the Data Protection Legislation.
3. The Supplier must notify the Customer within 10 business days if it receives a request from a Data Subject for access to their Personal Data or to exercise any of their other rights under the Data Protection Legislation.
4. The Supplier will give the Customer, at no additional cost to the Customer, its full co-operation and assistance in responding to any complaint, notice, communication or Data Subject request.
5. The Supplier must not disclose the Personal Data to any Data Subject or to a third party other than in accordance with the Customer's written instructions, or as required by domestic law.
Term and termination
1. This Agreement will remain in full force and effect so long as:
  1. the Services Agreement remains in effect; or
  2. the Supplier retains any of the Personal Data related to the Services Agreement in its possession or control (Term).
2. Any provision of this Agreement that expressly or by implication should come into or continue in force on or after termination of the Services Agreement in order to protect the Personal Data will remain in full force and effect.
3. The Supplier's failure to comply with the terms of this Agreement may be a material breach of the Services Agreement. In such event, the Customer may terminate the Services Agreement effective immediately on written notice to the Supplier without further liability or obligation of the Customer.
4. If a change in any Data Protection Legislation prevents either party from fulfilling all or part of its Services Agreement obligations, the parties may agree to suspend the processing of the Personal Data until that processing complies with the new requirements. If the parties are unable to bring the Personal Data processing into compliance with the Data Protection Legislation within 30 days, either party may terminate the Services Agreement on not less than10 working days written notice to the other party.
Data return and destruction
1. At the Customer's request, the Supplier will to the extent technically possible give the Customer, or a third party nominated in writing by the Customer, a copy of or access to all or part of any Customer Data in its possession or control in the format and on the media reasonably specified by the Customer.
2. On termination of the Services Agreement for any reason or expiry of its term, the Supplier to the extent technically possible will securely delete or destroy or, if directed in writing by the Customer, return and not retain, all or any of the Customer Data related to this Agreement in its possession or control.
3. If any law, regulation, or government or regulatory body requires the Supplier to retain any documents or materials or Customer Data that the Supplier would otherwise be required to return or destroy, it will notify the Customer in writing of that retention requirement, giving details of the documents, materials or Customer Data that it must retain, the legal basis for retention, and establishing a specific timeline for deletion or destruction once the retention requirement ends.
Records
1. The Supplier will keep detailed, accurate and up-to-date written records regarding any processing of the Personal Data, including but not limited to, the access, control and security of the Personal Data, the processing purposes, categories of processing, any transfers of personal data to a third country and related safeguards, and a general description of the technical and organisational security measures referred to in clause 5.1 (“Records”).
2. The Supplier will ensure that the Records are sufficient to enable the Customer to verify the Supplier's compliance with its obligations under this Agreement and the Supplier will provide the Customer with copies of the Records upon request.
Audit
1. On the Customer’s written request, at least once a year, the Supplier will conduct audits of its Personal Data processing practices and the information technology and information security controls for all facilities and systems used in complying with its obligations under this Agreement, including, but not limited to, obtaining a network-level vulnerability assessment performed by a recognised third-party audit firm based on recognised industry best practices.
2. On the Customer's written request, the Supplier will make all of the relevant audit reports available to the Customer for review, including as applicable: reports relating to its ISO/IEC 27001 certification and other relevant third party reports attesting to the Supplier’s compliance. The Customer will treat such audit reports as the Supplier's confidential information under the Services Agreement.
3. The Supplier will promptly address any exceptions noted in the audit reports with the development and implementation of a corrective action plan by the Supplier's management.
Warranties
1. The Supplier warrants and represents that:
  1. its employees, subcontractors, agents and any other person or persons accessing the Personal Data on its behalf are reliable and trustworthy and have received the required training on the Data Protection Legislation;
  2. it and anyone operating on its behalf will process the Personal Data in compliance with the Data Protection Legislation and other laws, enactments, regulations, orders, standards and other similar instruments;
  3. it has no reason to believe that the Data Protection Legislation prevents it from providing any of the Services Agreement's contracted services; and
  4. considering the current technology environment and implementation costs, it will take appropriate technical and organisational measures to prevent the unauthorised or unlawful processing of Personal Data and the accidental loss or destruction of, or damage to, Personal Data, and ensure a level of security appropriate to:
    1. the harm that might result from such unauthorised or unlawful processing or accidental loss, destruction or damage;
    2. the nature of the Personal Data protected; and
    3. comply with all applicable Data Protection Legislation and its information and security policies, including the security measures required in clause ‎5.1.
2. The Customer warrants and represents that the Supplier's expected use of the Personal Data for the Business Purposes and as specifically instructed by the Customer will comply with the Data Protection Legislation.
Use of Artificial Intelligence (“AI”)
1. The Company uses artificial intelligence and machine learning technologies in providing Services as such:
  1. The Company shall have the right to collect and analyse usage data and other information relating to the provision, use and performance of various aspects of the Services and the Company will be free to use such information and data, in aggregate and de-identified form, to improve and enhance the Services and for other development, diagnostic and corrective actions in relation to its software and/or Services.
  2. The Company will ensure that the software is designed, developed and tested in a way which ensures that its operation is sufficiently transparent to enable the Customer to understand and use the Services properly.
  3. In the unlikely event that the Company has access to personal data uploaded by the Customer, the Company confirms that it will not disclose personal data to any unauthorised third parties in de-aggregated or unredacted form.
  4. Upon written request from the Customer, the Company will delete the Customer Data, and shall provide confirmation to the Customer of the deletion within 60 business days.
2. The Company undertakes that: (a) it shall use Customer Data and Intellectual Property that has been submitted to the platform, and ingested by the Services solely for, and as the provision of its Services; and (b) Customer Data, Confidential Information and Intellectual Property Rights which have been ingested by the platform and/or Services shall not be disclosed to any third parties save for those sub processors set out in our Trust Centre https://security.robinai.com/.
3. We take the security of our Customer’s data and privacy seriously and additional information in respect of our commitment may be found at our Trust Centre https://security.robinai.com/.
4. The Company shall be permitted to retain any derivative works developed, generated, or derived in connection with the provision or use of the Services, provided that such derivative works do not contain any Customer Data.
Notice
1. Any notice, or other communication, given to a party under or in connection with this Agreement must be in writing and delivered to:

For the Customer: The email address or contact information provided by the Customer in their account settings, or as otherwise communicated to the Supplier in writing.

For the Supplier: compliance@robinai.com

Clause ‎15.1 does not apply to the service of any proceedings or other documents in any legal action or, where applicable, any arbitration or other method of dispute resolution.
Personal Data processing purposes and details

Subject matter of processing: Provision of the Services, including reviewing and analyzing relevant legal contracts.

Duration of Processing: For the term of the Services Agreement

Nature of Processing: For the purpose of the Customer being able to utilize the Software and the Supplier to provide support and services to the Customer under the Services Agreement

Business Purposes: For the purpose of providing services under the Services Agreement

Personal Data Categories: Name, contact details, other categories of Personal Data that may be embedded within uploaded contracts.

Data Subject Types: Employees, employees or representatives of Customer’s business customers, other third parties.

Authorised Persons: Robin AI Limited and Robin AI Inc. employees and contractors who are providing services under the Services Agreement.

a) Performance of a contract (Article 6(1)(b) UK/EU GDPR):

We process personal data where it is necessary to enter into or perform our contract with you or the organisation you represent, for example to:

• Provide and operate the Robin AI platform and related services;

• Manage user accounts, authentication, and billing;

• Provide customer support and respond to service requests.

(b) Legitimate interests (Article 6(1)(f)):

We process personal data where it is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms. Our legitimate interests include:

• Improving and developing our products and services;

• Ensuring the security and integrity of our systems;

• Monitoring service usage to detect fraud or misuse;

• Marketing to business contacts (subject to applicable marketing laws);

• Analyzing anonymised or aggregated usage data to enhance AI performance.

When relying on legitimate interests, we perform a balancing test to ensure that your interests and fundamental rights are not disproportionately affected.

We may process personal data to comply with our legal obligations, for example to:

• Maintain business records as required by law;

• Respond to lawful requests from regulators, tax authorities, or law enforcement.

(d) Consent (Article 6(1)(a)):

In some cases, we rely on your consent; for example, when sending certain marketing communications to individuals who are not existing customers, or when using optional cookies or analytics tools on our website. You may withdraw consent at any time by following the instructions in those communications or through our website settings.

Subprocessors: Robin AI engages certain third-party service providers (“Subprocessors”) to assist in delivering and supporting our services. The following is a current list of Subprocessors, along with the purposes for which they process data on our behalf.

AWS: Cloud Services Provider

Anthropic: Hosted software services: API based AI Services

Amazon Bedrock: AI model hosting and deployment platform

Amazon SageMaker: Machine learning model training and deployment

HubSpot: Customer relationship management and marketing automation

Snowflake: Data warehousing and analytics

Mix panel: Product analytics and user behavior tracking

Sentry: Error monitoring and performance tracking

Security measures

Robin's security measures are validated through SOC 2 Type II, ISO 27001:2022, and Cyber Essentials certifications, ensuring robust technical and organisational controls across all operations. Below is a detailed overview of our security framework:

Physical Access Controls

Data centres (hosted by AWS) enforce multi-layered security, including biometric authentication, 24/7 surveillance, security personnel, environmental monitoring (e.g., fire suppression, climate control), and restricted access zones. Only authorised AWS personnel can access physical infrastructure, with all activities logged and audited.

System Access Controls

- Role-Based Access Control (RBAC): Four permission levels (User, Admin, Owner, Internal) restrict system access based on job responsibilities.

- Authentication: Multi-factor authentication (MFA) is required for all systems handling sensitive data. Enterprise SSO integrates with SAML 2.0 (e.g., Azure AD) and OIDC (e.g., Okta).

- Session Management: Re-authentication occurs every 10 minutes for sensitive operations.

-Log Collection and Retention: Centralised Logging: All logs (authentication, access, system activities) are aggregated in AWS CloudWatch and Datadog, with immutable storage to prevent tampering.

Data Access Controls

- Tenant Segregation: Unique tenant IDs enforce complete isolation between customers. API requests require valid client-specific tokens.

- Least Privilege: Access is granted strictly based on role requirements. Customer data is accessible only to customers unless explicit prior authorisation is provided for support requests.

- Monitoring: Real-time alerts trigger for unauthorised access attempts.

-User Access: All login attempts (successful/failed), privilege changes, and data access are logged.

Transmission Controls

- All data in transit is encrypted via TLS 1.2+ or higher, including web applications, APIs, and database connections.

- Deprecated or insecure protocols (e.g., SSLv3, TLS 1.0) are prohibited.

- AWS Bedrock API communications use HTTPS exclusively.

-All records are encrypted (AES-256) and stored in geographically dispersed AWS regions for resilience.

Input Controls

- Validation: All user inputs are sanitised and validated to prevent attacks (e.g., SQL injection).

- Malware Scanning: Uploaded files are automatically scanned using ClamAV.

- Audit Logs: All input activities are logged with tenant context.

Data Backups

- Frequency: Continuous point-in-time recovery for S3 buckets and databases, with 30-day retention.

- Testing: Automated restoration tests occur weekly to verify backup integrity.

- Encryption: Backups are encrypted using AES-256 with keys managed via AWS KMS.

- Geographical Distribution: Backups are replicated across multiple AWS availability zones.

- Disaster Recovery: RTO (Recovery Time Objective) of ≤4 hours and RPO (Recovery Point Objective) of ≤1 hour for critical systems.

Data Segregation

- Logical Isolation: Tenant IDs are the primary filtering mechanism in all database queries, ensuring zero cross-tenant data exposure.

- AI Processing: AI models (e.g., Anthropic Claude via AWS Bedrock) process data within isolated tenant contexts.

- Encryption: Data at rest is encrypted using AES-256, with tenant-specific keys where applicable.