Data Processing Agreement (DPA)

1. Parties, roles and scope

This Data Processing Agreement ("DPA") forms part of the Terms and conditions and Privacy policy of Sice, based in Santa Cruz de la Sierra, Bolivia, and governs the processing of personal data when a business or organization (the "Customer") uses a workspace on Sice.

The Customer acts as the data controller of the personal data it loads about its own customers, patients, leads or staff, and is responsible for holding the required legal basis, privacy notices and consents. Sice acts solely as the data processor (or service provider under equivalent laws), processing that data on behalf of the Customer and in accordance with its documented instructions.

2. Subject matter, duration and nature of processing

• Subject matter and purpose: providing the subscribed modules, the workspace, the artificial intelligence features and the integrations connected by the Customer, without selling or sharing personal data for third-party cross-context behavioral advertising.
• Duration: for as long as the Customer's workspace remains active, plus the retention and deletion period in section 4.
• Categories of data subjects: customers, prospects, patients, suppliers, visitors to the Customer's websites and members of the Customer's team.
• Types of personal data: contact and identification details, commercial and accounting records, conversations and messages (email, WhatsApp, chat), documents and files, employment records (if the Customer switches on Human resources), clinical and health records (if the Customer switches on Health) and on-demand prospecting location.

3. Sice's obligations as processor

• Documented instructions: process personal data solely to provide the service in accordance with the Terms and conditions, the workspace configuration and the actions the Customer performs in the app or API, informing the Customer if an instruction conflicts with applicable law.
• Confidentiality and staff logging: ensure that everyone authorized to process data on behalf of Sice is bound by confidentiality obligations, logging every administrative action by support staff in immutable audit trails.
• Technical and organizational security: maintain the isolation and encryption safeguards described in section 5.
• Assistance with data-subject rights: help the Customer respond to access, rectification, erasure, objection and portability requests through the modules' native CSV, Excel and PDF exports or by providing a full copy upon request.
• Security incident notification: notify the Customer of any confirmed security incident affecting personal data in its workspace without undue delay and within 72 hours of confirmation, stating the known scope and mitigation measures taken.
• Assessments and audits: provide the technical information needed to demonstrate compliance with this DPA and allow up to one reasonable audit per year (or following a confirmed incident), with 30 days' prior notice and protecting the confidentiality of other customers.

4. End of service and cryptographic erasure

When the Customer deletes its workspace from inside the app, it remains 30 days in a recoverable state ("deleted") in case the Customer wishes to restore it, or is purged earlier if the workspace owner expressly requests immediate erasure. Once that period expires, Sice permanently deletes the workspace's database, files, API keys and domains, and destroys its encryption keys (cryptographic erasure), rendering earlier copies unreadable until backups roll over within about two weeks.

Outstanding Sice platform invoices never block or delay the deletion of personal data belonging to the workspace's customers or patients; Sice retains only its own tax invoices as required by law. Full details are in Data deletion.

5. Technical and organizational measures (Security annex)

• Per-workspace isolation: every workspace runs on its own isolated database and its own set of encryption keys.
• Encryption in transit and at rest: all connections use TLS. Secrets, integration tokens, mailbox passwords, personal email bodies and chat rooms are encrypted with AES-256-GCM using per-workspace and per-person data keys wrapped by a master key kept outside the database, allowing any workspace's or user's keys to be rotated or destroyed without affecting others.
• Enhanced clinical data protection: in the Health module, consultation text (chief complaint, SOAP notes, diagnostic notes and additional notes), epidemiological surveillance notes, and documents and PDFs in the patient's folder are stored encrypted at rest with AES-256-GCM under the workspace's key. Every clinical access is recorded in an append-only audit log and signed consultations only accept dated addenda.
• Access control and authentication: granular permissions per module and action, two-factor authentication (TOTP and WebAuthn passkeys), account lockout on failed attempts, revocable sessions, and per-account and per-IP rate limits.
• Verified backups: daily database backups with periodic automated restore checks in an isolated environment.

6. Binding list of subprocessors and advance notice

The Customer grants Sice general authorization to engage the following subprocessors, each strictly limited to the stated function:

• Anthropic, PBC (United States): processing text prompts, assistants and AI agents when the Customer uses artificial intelligence features.
• Google LLC (United States): Gemini and Veo models for AI image and video generation, Firebase Cloud Messaging for push notifications, and Google Maps Platform for maps and addresses.
• Zoho Corporation (United States and European Union): delivery of transactional system emails (security codes, invitations and operational notices).
• Meta Platforms, Inc. (United States): delivery of verification codes and notices via the WhatsApp Cloud API, plus WhatsApp Business, Facebook, Instagram and Threads channels when the Customer connects its own accounts.
• OpenStreetMap Foundation (United Kingdom and European Union): address geocoding and map search (Nominatim).
• TikTok, LinkedIn and Microsoft (United States and the Customer's account region): publishing, messaging, ads, email or calendar, solely when the Customer chooses to connect those integrations in its workspace.
• Servicio de Impuestos Nacionales — SIN (Bolivia): electronic tax invoicing, solely if the Customer switches on and configures the tax integration in Bolivia.

Sice imposes data protection and confidentiality obligations equivalent to this DPA on every subprocessor. Before adding a new subprocessor or replacing an existing one, Sice will notify the workspace owner by email and update this page at least 30 days in advance, allowing the Customer to object on reasonable data protection grounds or terminate the affected service without penalty.

7. International transfers and contact

Whenever engaging the subprocessors in section 6 involves processing personal data outside the Customer's country (including from the European Economic Area, the United Kingdom, Switzerland, Brazil or California), Sice applies the required legal safeguards, including the European Commission's Standard Contractual Clauses (EU Decision 2021/914, processor-to-processor or controller-to-processor module as applicable), the equivalent clauses under Brazil's LGPD, and service-provider commitments under the California CCPA/CPRA.

For any question, audit request or notice regarding this DPA, write to contact@sice.site, on WhatsApp at +591 62134124 or through our contact page.