Data Processing Agreement

1. Description of the processing

The customer does not submit special categories of data under Article 9 GDPR unless it has a legal basis to do so and has told Munimen.

2. Customer instructions

Munimen processes data only on the customer’s documented instructions: the terms of service, this agreement and the settings made in the Service (connected tools, spaces, rights, chosen model). If an instruction seems to breach applicable law, Munimen tells the customer.

Customer data is never used to train any AI model, neither by Munimen nor by its subprocessors.

3. AI models

Search, indexing and ranking rely on models run by Munimen on its own infrastructure in France. Content extraction and structuring, as well as default answers, use Mistral AI, in the European Union.

The customer may choose another model to generate answers, on its own account (for example OpenAI, Anthropic, Google, Azure OpenAI, Amazon Bedrock or Ollama). That provider then receives the questions and the passages needed for the answer; this transfer is made on the customer’s instruction, under the customer’s own contract with that provider. The rest of the data processing stays with Munimen and Mistral AI.

4. Confidentiality

Everyone authorized to process customer data is bound by confidentiality. Access to production data is limited to the people who need it.

5. Security

Munimen implements and maintains in particular the following measures:

• hosting in the AWS Paris region (France);
• encryption in transit and at rest; indexed content is encrypted with a key dedicated to each organization, managed by AWS KMS;
• each organization’s data isolated in its own database schema;
• access rights set per space, strong authentication (SAML and OIDC SSO, two-factor authentication, passkeys);
• daily backups kept for seven days;
• optionally, on request: a customer-managed key held outside AWS (XKS) and processing in isolated AWS Nitro Enclaves.

6. Subprocessors

The customer authorizes Munimen to use the following subprocessors. Munimen binds them by contract to obligations equivalent to this agreement and remains liable for their acts.

Munimen informs the customer of any addition or replacement at least thirty days in advance. The customer may object on reasonable data protection grounds; failing agreement, it may terminate at no cost.

7. Transfers outside the European Union

Transfers to a third country are covered by the European Commission’s standard contractual clauses (Decision 2021/914), or by the Data Privacy Framework for certified companies, supplemented where needed by additional measures.

8. Assistance to the customer

Munimen helps the customer, as far as possible, to answer data subject requests, in particular through the Service’s export and deletion features, and to carry out impact assessments and prior consultations.

Munimen notifies the customer of any personal data breach without undue delay and no later than 48 hours after becoming aware of it, at the organization’s contact address, with the information available for the customer’s own notification.

9. End of processing

When the Service ends, the customer has thirty days to export its content. Data is then deleted from active systems, the organization’s dedicated encryption key is destroyed, and the data is gone from backups within thirty days, unless the law requires it to be kept.

10. Audit

Munimen makes available to the customer the information needed to demonstrate compliance with this agreement. The customer may run an audit once a year, at its own cost, with thirty days’ notice, through an auditor bound by confidentiality and without access to other customers’ data.

11. General provisions

The parties’ liability under this agreement follows the terms of service. This agreement is governed by French law; the competent courts of Paris have exclusive jurisdiction.

Contact: privacy@munimen.ai, or Kilian Bodet--Canac, 60 rue François Ier, 75008 Paris, France.