Draft, attorney review pending. This notice describes our current practices accurately to the best of our knowledge and will be replaced with attorney-reviewed language before general commercial release.
Data Processing Addendum
Last updated: September 3, 2026
This Data Processing Addendum (this "DPA") is incorporated into the Terms of Service at /terms between Genstrata, Inc. ("Genstrata," the Processor) and the Customer identified in those Terms (the Controller). It governs Genstrata's processing of personal data about recipients and prospects that Customer submits to Apograph.
This DPA is a draft pending attorney review. It describes the roles we actually operate under. It is not a substitute for a signed DPA if your counsel requires one.
1. Roles
Customer is the controller of recipient and prospect personal data. Genstrata is a processor (service provider) acting only on Customer's documented instructions: to host, research, draft, verify, and present that data in the Service. For account, usage, and contact-form data, Genstrata is an independent controller as described in the Privacy Policy at /privacy.
2. Instructions
Customer instructs Genstrata to process Customer Content and Output as needed to provide the Service, including transmitting relevant text to subprocessors listed at /subprocessors. Customer is responsible for the lawfulness of the data it submits and for notices to recipients where law requires them.
3. Confidentiality and security
Genstrata will ensure persons authorized to process the data are bound by confidentiality. Security measures are described in the Privacy Policy. Genstrata will notify Customer without undue delay after becoming aware of a personal-data breach affecting Customer Content.
4. Subprocessors
Customer authorizes Genstrata to engage the subprocessors listed at /subprocessors. Genstrata remains responsible for their performance. Change notice is as stated on that page.
5. Assistance, deletion, and audit
Genstrata will reasonably assist Customer with data-subject requests referred to Customer under the Privacy Policy. After termination, Genstrata will delete or return Customer Content as described in the Terms. On written request, Genstrata will make available information reasonably necessary to demonstrate compliance with this DPA.
6. Contact
Genstrata, Inc., a Delaware corporation.
Legal: legal@genstrata.com. Privacy: privacy@genstrata.com. Security: security@genstrata.com. General: info@genstrata.com.
Postal address for service of process: write legal@genstrata.com for the current Delaware registered-agent street address on file with the Division of Corporations.