Last Updated on July, 10, 2025 | Version 1.1
This DPA is entered between:
Controller: Client
Processor: Quantum Neuron Inc.
1. Purpose and Scope
Quantum Neuron Inc. processes personal data solely to provide AI-based Persona communication services.
2. Data Transfers and Sub-processors
Transfers outside the EEA are subject to SCCs (2021/914/EU). Sub-processing may involve third parties as listed at https://quantumneuron.ai/legal/subprocessors.
3. Anonymized Data for AI Training
Sessions marked as "helpful" or "completed" may be anonymized and used to train AI models, with the objective of improving model accuracy, response safety, task completion rates, and domain-specific performance of proprietary AI communication systems. Once anonymized, the data is not considered personal under GDPR and is exempt from erasure obligations.
4. Security Measures
Quantum Neuron maintains appropriate technical and organizational security controls, including:
Encrypted storage and transit
Role-based access
Regular audits
5. Data Protection Impact Assessment (DPIA) – AI Training on Anonymized Data
Purpose
To assess risks associated with reusing anonymized conversation data for AI model training.
Legal Basis
Consent (Art. 6(1)(a) GDPR)
Legitimate interest fallback (Art. 6(1)(f))
Data Flow Overview
Live Persona session → rated or completed → anonymized → AI training pipeline
Risk Analysis
Re-identification from vector embeddings
Vector inversion
Sub-processor access exposure
Mitigations
All identifiers stripped via script
No raw logs enter training datasets
Controlled access to logs
Retention limited to training relevance
