For the build phase of an ADAMAS engagement, the client is the data controller and Falcon Intelligence Group LLC ("we") is the data processor for the material the client shares with us for setup (Art. 28 GDPR). Once the vault is handed over, processing happens on the client's own hardware under the client's sole control — we are no longer a processor for vault contents, retain no access, and hold no copy.
Processing is limited to: configuring the client's vault, connecting agreed sources, seeding the decision ledger from material the client provides, and verifying the system before handover. Duration: from engagement start until handover plus an agreed wind-down period, after which all client material in our possession is deleted or returned (client's choice), with deletion confirmed in writing.
Typically: business contact data and business communications of the client's personnel, clients, and suppliers, as contained in the sources the client chooses to connect (e.g., email, team chat, CRM, documents, meeting transcripts). The client decides which sources and scopes are included; special categories of data are not requested and should be excluded from connected scopes.
General authorisation with prior notice of changes. Current sub-processors for the build phase are listed on the Security page (Netlify, Plausible, Google — for website, scheduling, and correspondence only). The Hermes AI agent runs locally on the client's hardware and does not receive client data on its provider's servers. The optional hybrid cloud route transmits data only with the client's explicit per-task approval and is disabled by default.
Where the build phase involves transfers from the EEA, the UK, or Switzerland to the United States, the parties rely on the European Commission's Standard Contractual Clauses (Module 2, controller-to-processor) with the UK Addendum where applicable, incorporated into the executed agreement.
Liability and governing law follow the main services agreement between the parties. In case of conflict between this DPA and the main agreement regarding data protection, this DPA prevails.
Questions about this template: privacy@adamas-project.com. The local-first boundary that makes most of this short: Security & data ownership.