Data Processing Agreement – Quantum Neuron

Data Processing Agreement – Quantum Neuron

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