Inclutra Legal

Data Processing Addendum (DPA)

This DPA applies when you use Inclutra as a business or organization and we process personal data on your behalf.

Contents Expand
  1. § 1. Parties and Roles
  2. § 2. Scope of Processing
  3. § 3. Controller Instructions
  4. § 4. Confidentiality
  5. § 5. Subprocessors
  6. § 6. Security and Incidents
  7. § 7. Data Subject Rights
  8. § 8. Compliance Assistance
  9. § 9. Audits
  10. § 10. Return and Deletion
  11. § 11. How This DPA Becomes Binding
  12. § 12. Contact

§ 1 Parties and Roles

§ 1.1 You are the Controller. Inclutra is the Processor.

§ 1.2 Inclutra is operated by Alexander Duggleby (sole proprietorship), trading as Inclutra, Marxergasse 24/2, 1030 Wien, Austria.

§ 2 Scope of Processing

§ 2.1 We process personal data only to provide Inclutra services to you.

§ 2.2 Processing scope includes account data, transcript and translation data, and transient live audio processing needed to generate transcript and translation output.

§ 2.3 Neither Inclutra nor any of our subprocessors store raw audio.

§ 3 Controller Instructions

§ 3.1 We process personal data only on your documented instructions, including configuration and actions performed by authorized users in your account.

§ 3.2 If we believe an instruction infringes applicable data protection law, we will inform you without undue delay.

§ 4 Confidentiality

§ 4.1 We ensure that persons authorized to process personal data are bound by confidentiality obligations.

§ 5 Subprocessors

§ 5.1 We use the following subprocessors.

  • Hetzner (Germany) for hosting and storage.
  • Gladia (France) for transcription and translation processing.
  • Lettermint (Netherlands) for transactional email delivery.

§ 5.2 Inclutra analytics, telemetry, and logging are self-hosted by us in the EU.

§ 5.3 You provide general authorization for these subprocessors. We will notify you of intended material changes to subprocessors, and we will impose data protection obligations on subprocessors that are no less protective than those in this DPA.

§ 6 Security and Incidents

§ 6.1 We implement appropriate technical and organizational security measures for the services.

§ 6.2 If we become aware of a personal data breach affecting your data, we will notify you without undue delay.

§ 7 Data Subject Rights

§ 7.1 We provide reasonable assistance to help you respond to data subject requests under applicable law.

This includes requests for:

  • access (subject access requests)
  • rectification
  • erasure
  • restriction of processing
  • data portability (where applicable)
  • objection to processing (where applicable)
  • rights related to automated decision-making, where relevant

§ 7.2 You remain responsible for handling and answering data subject requests as Controller. Inclutra assists by providing available information and technical support within the scope of the services.

§ 8 Compliance Assistance

§ 8.1 Taking into account the nature of processing and information available to us, we provide reasonable assistance for your compliance obligations under GDPR and UK GDPR, including security of processing, personal data breach notification, data protection impact assessments, and prior consultation where required.

§ 9 Audits

§ 9.1 We make available all information reasonably necessary to demonstrate compliance with this DPA and applicable processor obligations.

§ 9.2 We support audit rights through documentation review by default. Where required by law or regulator request, and subject to reasonable notice, confidentiality, and security safeguards, we will also permit and contribute to audits or inspections by you or your mandated auditor.

§ 9.3 We can provide one signed PDF copy of this DPA on request once per year, or earlier if this DPA changes.

§ 9.4 We do not offer separate audit procedures unless agreed in writing in an enterprise contract.

§ 10 Return and Deletion

§ 10.1 Upon your written instruction, we will return or delete personal data, unless retention is required by applicable law.

§ 10.2 As a default service setting, customer data remains available until you delete account data or content from your dashboard, subject to legal retention obligations.

§ 11 How This DPA Becomes Binding

§ 11.1 This DPA is incorporated into your service agreement by reference. It becomes binding when you accept Inclutra terms during account signup and registration.

§ 11.2 For enterprise procurement, a signed PDF version of this DPA is available on request under the audit and signature cadence above.

§ 12 Contact

§ 12.1 DPA requests and questions : hello@inclutra.com.

Last updated: 2026-02-28.