Data Processing Addendum

Last updated: [date of publication]

This Data Processing Addendum ("DPA") forms part of the Trellis Terms of Service or other agreement (the "Agreement") between Hager Investments LLC, doing business as Trellis ("Trellis"), and the Customer. It applies whenever Trellis processes Customer Personal Data in providing the Service.

1. Definitions

• Customer Personal Data means personal data within Customer Data that Trellis processes on the Customer's behalf in providing the Service.
• Data Protection Laws means the privacy and data protection laws that apply to the processing, including US state laws such as the California Consumer Privacy Act as amended, [and, where applicable, the GDPR and UK GDPR].
• Security Incident means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Customer Personal Data.
• Subprocessor means a third party Trellis engages to process Customer Personal Data.
• Other capitalised terms have the meaning in the Agreement. "Controller", "processor", "business" and "service provider" have the meanings in the Data Protection Laws.

2. Roles

The Customer is the controller (or "business") of Customer Personal Data, and Trellis is its processor (or "service provider"). Trellis is the controller only of account, billing and website data, which its Privacy Policy covers.

3. Instructions

3.1 Trellis processes Customer Personal Data only on the Customer's documented instructions. The Agreement, the Customer's configuration of the Service, and actions its users take in the Service (for example, importing a document, which sends it to the AI provider) are the Customer's instructions.

3.2 Trellis will tell the Customer if it believes an instruction breaks Data Protection Laws, and is not required to follow it.

3.3 As a service provider, Trellis will not sell or share Customer Personal Data, retain, use or disclose it for any purpose other than providing the Service, or combine it with personal data it receives from others, except as the Data Protection Laws permit.

4. Confidentiality of people

Trellis ensures that anyone it authorizes to process Customer Personal Data is bound by confidentiality. Today that is Trellis's founder only.

5. Security

5.1 Trellis implements the technical and organizational measures in Annex 2, which describe the Service as it is today, including what is not yet in place. Trellis may update them, provided the overall level of protection does not fall.

5.2 The Customer is responsible for the security of its own users' accounts, for who it makes an admin, and for choosing which features to use, including the AI features described in Annex 1.

6. Subprocessors

6.1 Authorization. The Customer authorizes Trellis to use the Subprocessors listed in Annex 3 and on the Subprocessors page.

6.2 Changes. Trellis will give the Customer's admins at least [30] days' notice by email before adding or replacing a Subprocessor. If the Customer reasonably objects on data protection grounds within that period, the parties will discuss it in good faith; if they cannot resolve it, the Customer may terminate the affected Service and receive a refund of prepaid fees for the unused term.

6.3 Flow-down. Trellis imposes data protection terms on each Subprocessor that protect Customer Personal Data at least as well as this DPA, and remains responsible for its Subprocessors' performance.

7. Requests from individuals

Trellis will help the Customer respond to requests from individuals exercising their rights, mainly through the Service's own features (admins can correct and remove members, and export the plan). If Trellis receives a request directly, it will pass it to the Customer and not respond itself, unless the law requires.

8. Security Incidents

8.1 Trellis will notify the Customer without undue delay, and in any case within [72 hours], after becoming aware of a Security Incident affecting Customer Personal Data.

8.2 The notice will describe, as far as then known, what happened, the data and people affected, the likely consequences, and what Trellis is doing about it, and Trellis will update it as more is learned.

8.3 Notifying an incident is not an admission of fault.

9. Assistance

Trellis will give the Customer reasonable help with data protection impact assessments and with consultations with regulators that relate to the Service, taking into account the information available to Trellis.

10. Deletion and return

At the end of the Agreement, or earlier on the Customer's written request, Trellis will export the Customer's workspace for the Customer (the plan, its people and its audit trail) and then delete Customer Personal Data from the Service within [30] days, and confirm deletion in writing, except where the law requires it to be kept. Copies in backups are deleted as the backups expire.

11. Location and transfers

11.1 Trellis stores Customer Personal Data in the United States.

11.2 The AI provider (Anthropic) stores data in the United States, and Trellis requests US-only processing on every call, so Customer Personal Data sent to it is processed in the United States.

12. Audits

12.1 Trellis will make available the information reasonably necessary to show compliance with this DPA: its Security page, written answers to reasonable security questionnaires [once a year], and, when it has them, third-party reports.

12.2 Any further audit is by agreement, at the Customer's cost, on reasonable notice, during business hours, and subject to confidentiality.

13. Liability and order of precedence

Each party's liability under this DPA is subject to the limits in the Agreement. If this DPA conflicts with the Agreement on the processing of Customer Personal Data, this DPA prevails.

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Annex 1: Details of processing

Annex 2: Technical and organizational measures

As described on the Trellis Security page (trellisexecution.com/security), in summary:

1. Isolation between customers: every query scoped to the workspace; every action gated on the person's rights, checked by an automated test of the source; 61 database relationships that include the workspace in the key, so the database refuses cross-company links; an isolation exercise across six paths, run automatically every week, last passed 2026-10-03; a CI check that no database migration removes one of those relationships. Not yet in place: Postgres row-level security (planned with the production cutover).
2. Integrity: append-only measure readings; an audit trail of every change to the plan (actor, action, before, after, time), written in the same transaction; downloads of the plan and the start of an admin's preview as another member are recorded too. Reading the plan on screen is not logged.
3. Encryption: TLS in transit with HTTP Strict Transport Security; encryption at rest by Neon and Vercel Blob; hashed one-time tokens for update links; device-encrypted push messages.
4. Access control: two permission levels (Admin, Viewer); rights to change records derived from the plan; no Trellis support login or impersonation. Not yet in place: a log of Trellis operator access to the database.
5. Files: private storage; served only through the Service, scoped to the workspace, with restrictive headers.
6. Availability and recovery: hosted on Vercel and Neon; Neon history and restore, rehearsed 2026-10-10; Neon keeps 7 days of history.
7. Development practice: every change reviewed in a pull request, typechecked and tested in CI; the weekly isolation exercise (see 1); schema changes applied by the production build only.
8. AI: every call to the AI provider requests US-only processing, enforced by a test; admins can turn AI drafting off; importing asks for confirmation on every upload.

Annex 3: Subprocessors

When payments open: Stripe [legal entity to confirm] (billing contacts and payment details; Trellis never receives card numbers).

Version 3b83647, 2026-10-10.