LegalData Processing Addendum
Enterprise Document

Data Processing
Addendum

This DPA forms part of the agreement between Engineersmind Corp ("Processor") and the customer entity that has accepted those terms ("Controller"). It governs the processing of Personal Data by Engineersmind Corp on behalf of the Customer in connection with the PDFFillr platform and related services.

Last Updated: April 8, 2026Jersey City, NJ, United StatesEnterprise & B2B Customers

Enterprise & B2B Customers

This DPA forms part of the Agreement, which consists of the Terms of Use, the Privacy Policy, the Service Level Agreement, and, for enterprise customers, the SaaS Agreement and applicable Order Form(s). In the event of any conflict with respect to data processing obligations, this DPA takes precedence. For a separately executed DPA or additional contractual commitments, contact Support@pdffillr.ai.

01

Definitions

For the purposes of this DPA, the following terms have the meanings set out below. Capitalized terms not defined here have the meanings given to them in the Agreement or the applicable Privacy Policy.

Controller

The Customer, being the natural or legal person who determines the purposes and means of the processing of Personal Data submitted through the Services.

Processor

Engineersmind Corp, which processes Personal Data on behalf of the Controller in accordance with this DPA.

Data Subject

The identified or identifiable natural person to whom Personal Data relates.

Personal Data

Any information relating to an identified or identifiable natural person processed by the Processor on behalf of the Controller in connection with the Services.

Sensitive Personal Data

Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, data concerning a person's sex life or sexual orientation, financial account data, government-issued identification numbers, or any other category of data treated as sensitive under applicable law.

Processing

Has the meaning given to it under applicable Data Protection Law and includes any operation performed on Personal Data.

Data Protection Law

All applicable laws and regulations relating to privacy and the processing of Personal Data, including without limitation the GDPR (EU) 2016/679, the UK GDPR and Data Protection Act 2018, the CCPA/CPRA, and any other applicable national or state privacy laws, as amended or supplemented from time to time.

Security Incident

Any confirmed unauthorized access, acquisition, disclosure, alteration, or destruction of Personal Data processed under this DPA.

Sub-processor

Any third party engaged by the Processor to process Personal Data on behalf of the Controller.

SCCs

The standard contractual clauses for the transfer of personal data to third countries as approved by the European Commission under Commission Implementing Decision (EU) 2021/914, and/or the equivalent mechanism approved under UK law, as applicable.

02

Subject Matter, Nature, and Purpose of Processing

2.1 Subject Matter

The Processor shall process Personal Data submitted by or on behalf of the Controller through the Services solely for the purpose of providing the PDFFillr platform, including automated document analysis, PDF form population, file storage, and related functionality.

2.2 Nature of Processing

Processing activities include collection, storage, analysis, transformation, retrieval, transmission, and deletion of Personal Data contained in documents and files uploaded or generated through the Services.

2.3 Purpose

The Processor shall process Personal Data solely to provide the Services as described in the Agreement and as instructed by the Controller. The Processor shall not process Personal Data for any other purpose, including for the development or training of artificial intelligence models.

2.4 Duration

Processing shall continue for the duration of the Agreement and until all Personal Data is deleted or returned in accordance with Section 10 of this DPA.
03

Categories of Data Subjects and Personal Data

3.1 Categories of Data Subjects

Personal Data processed under this DPA may relate to the Controller's customers, clients, employees, contractors, end users, and other individuals whose Personal Data is contained in documents submitted through the Services.

3.2 Categories of Personal Data

Personal Data processed may include: names, email addresses, postal addresses, telephone numbers, and other contact details; government-issued identification numbers such as passport, driver's license, and national ID numbers; financial account information including account numbers, routing numbers, tax identification numbers, and transaction data; health and medical information; employment and professional information; and other Personal Data contained in documents submitted by the Controller.

3.3 Sensitive Personal Data

The Controller acknowledges that documents submitted through the Services may contain Sensitive Personal Data, including health information, financial data, and government-issued identification. The Controller is responsible for ensuring that any submission of Sensitive Personal Data through the Services is made in accordance with applicable Data Protection Law and that an appropriate legal basis exists for such processing.
04

Obligations of the Controller

The Controller represents, warrants, and agrees that it shall comply with all applicable Data Protection Law in connection with its use of the Services and its instructions to the Processor. Specifically, the Controller shall:

  • Ensure that it has a valid legal basis under applicable Data Protection Law to submit Personal Data to the Services and to authorize the Processor to process such Personal Data on its behalf;
  • Ensure that it has provided all required notices to, and obtained all required consents from, Data Subjects as necessary under applicable law;
  • Ensure that its instructions to the Processor are lawful and do not require the Processor to violate any applicable law;
  • Be solely responsible for determining the appropriateness of using the Services for processing the categories of Personal Data it submits, including Sensitive Personal Data.
05

Obligations of the Processor

The Processor shall:

  • Process Personal Data only in accordance with the documented instructions of the Controller, including as set out in this DPA and the Agreement, unless otherwise required by applicable law;
  • Ensure that persons authorized to process Personal Data are subject to appropriate confidentiality obligations;
  • Implement and maintain the technical and organizational security measures described in Section 8;
  • Assist the Controller in fulfilling its obligations to respond to Data Subject rights requests, as described in Section 9;
  • Notify the Controller of any Security Incident in accordance with Section 11;
  • Cooperate with and assist the Controller in conducting data protection impact assessments where required under applicable law;
  • Make available to the Controller all information reasonably necessary to demonstrate compliance with this DPA and cooperate with audits or inspections as set out in Section 13;
  • Upon termination or expiry of the Agreement, delete or return Personal Data in accordance with Section 10.
06

Sub-Processors

6.1 Authorization

The Controller hereby grants the Processor general authorization to engage Sub-processors for the purpose of providing the Services, subject to the conditions set out in this Section 6.

6.2 Current Sub-processors

The Processor currently engages the following Sub-processors in connection with the Services:
Sub-processorPurposeLocation
Amazon Web Services (AWS Bedrock)AI processing and cloud infrastructureUnited States
Anthropic (Claude)AI model inference and document processingUnited States
OpenAIAI model inference and document processingUnited States
Google DriveDocument storage and file integrationUnited States
DropboxDocument storage and file integrationUnited States

An up-to-date list of Sub-processors is available upon request by contacting Support@pdffillr.ai.

6.3 Changes to Sub-processors

The Processor shall provide the Controller with reasonable advance notice (no less than thirty (30) days) before engaging any new Sub-processor or making material changes to existing Sub-processor arrangements. If the Controller reasonably objects to the engagement of a new Sub-processor on grounds related to Data Protection Law, the Controller shall notify the Processor in writing within fourteen (14) days of receiving notice. The parties shall work in good faith to resolve the objection. If the parties are unable to resolve the objection, either party may terminate the affected portion of the Services upon written notice, without liability for such termination.

6.4 Sub-processor Obligations

The Processor shall impose data protection obligations on all Sub-processors that are no less protective than those set out in this DPA. The Processor remains liable to the Controller for the acts and omissions of its Sub-processors to the same extent the Processor would be liable if performing the services directly.
07

International Data Transfers

7.1 Transfers Outside the EEA/UK

Where Personal Data originating in the European Economic Area, United Kingdom, or Switzerland is transferred to a country that has not been recognized as providing an adequate level of data protection, such transfers shall be subject to appropriate safeguards as required under applicable Data Protection Law.

7.2 Standard Contractual Clauses

To the extent that any such transfer requires a legal transfer mechanism, the parties agree that the applicable SCCs are hereby incorporated into and form part of this DPA. The Module Two (Controller to Processor) SCCs shall apply where the Controller is the data exporter and the Processor is the data importer. The relevant Annexes to the SCCs shall be deemed completed with the information set out in this DPA and the Agreement. For transfers from the UK, the applicable UK Addendum to the SCCs shall also apply.

7.3 Additional Safeguards

The Processor shall implement any additional technical or contractual safeguards reasonably required by the Controller or applicable supervisory authority to ensure an adequate level of protection for transferred Personal Data.

A signed copy of the applicable SCCs can be requested by contacting Support@pdffillr.ai.

08

Technical and Organizational Security Measures

The Processor shall implement and maintain appropriate technical and organizational measures to protect Personal Data against unauthorized or unlawful processing and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Such measures include, at a minimum:

  • Encryption of Personal Data in transit and at rest using industry-standard protocols;
  • Role-based access controls limiting access to Personal Data to authorized personnel on a need-to-know basis;
  • Internal data minimization practices consistent with the principle of purpose limitation;
  • Regular security monitoring, logging, and audit capabilities;
  • Incident response and breach notification procedures;
  • Vendor management and sub-processor oversight controls.

The Processor may update or modify these measures from time to time, provided that any such updates do not materially reduce the overall level of protection afforded to Personal Data.

Full details of technical and organizational measures are set out in Annex II. Additional information for enterprise due diligence is available upon request at Support@pdffillr.ai.

09

Data Subject Rights

9.1 Controller Responsibility

The Controller is primarily responsible for responding to requests from Data Subjects exercising their rights under applicable Data Protection Law, including rights of access, rectification, erasure, restriction of processing, data portability, and objection.

9.2 Processor Assistance

The Processor shall, to the extent technically feasible and upon written request from the Controller, provide reasonable assistance to the Controller in responding to Data Subject rights requests, taking into account the nature of the processing. Such assistance shall include providing the Controller with access to relevant Personal Data within the Services and facilitating deletion or correction of Personal Data at the Controller's direction. The Processor shall promptly forward to the Controller any Data Subject rights request received directly by the Processor that relates to Personal Data processed on behalf of the Controller.
10

Data Deletion and Return

10.1 During the Term

The Controller may delete Personal Data and User Content at any time through the Services. Upon deletion by the Controller, Personal Data will be removed from active systems within thirty (30) days and may persist for up to ninety (90) days in encrypted backup systems, which are not actively accessed and are overwritten in the ordinary course of backup rotation.

10.2 Upon Termination

Upon expiry or termination of the Agreement, the Processor shall, at the Controller's election, either securely delete or return all Personal Data processed on behalf of the Controller within thirty (30) days, and shall certify such deletion in writing upon request. The Processor may retain Personal Data to the extent required by applicable law, in which case the Processor shall notify the Controller of such retention and shall continue to protect the retained Personal Data in accordance with this DPA.

Deletion from active systems will be completed within 30 days of termination. Encrypted backup copies may persist for up to 90 days and will be overwritten in the ordinary course of backup rotation.

11

Security Incidents and Data Breach Notification

11.1 Notification Obligation

The Processor shall notify the Controller without undue delay, and in any event within seventy-two (72) hours of becoming aware of a confirmed Security Incident affecting Personal Data processed on behalf of the Controller.

11.2 Content of Notification

Notification shall include, to the extent then known: a description of the nature of the Security Incident, including the categories and approximate number of Data Subjects affected; the name and contact details of a data protection contact from whom further information may be obtained; a description of the likely consequences of the Security Incident; and a description of the measures taken or proposed to address the Security Incident, including where appropriate measures to mitigate its possible adverse effects.

11.3 Cooperation

The Processor shall cooperate with the Controller and take such reasonable steps as directed by the Controller to assist in investigating, mitigating, and remediating each Security Incident. Where notification to a supervisory authority or Data Subjects is required under applicable law, the Controller shall be responsible for making such notifications, and the Processor shall provide reasonable assistance.

Breach notifications will be sent to the primary account email address. Ensure your contact details are kept current to receive timely notifications.

12

Confidentiality

The Processor shall ensure that all personnel authorized to process Personal Data on behalf of the Controller are subject to binding confidentiality obligations with respect to that Personal Data, whether by contract or statutory duty. Such obligations shall survive the termination of the relevant person's engagement with the Processor.

13

Audit Rights and Compliance Cooperation

13.1 Information and Audit

Upon reasonable written request from the Controller (no more than once per calendar year absent reasonable cause), the Processor shall make available to the Controller all information reasonably necessary to demonstrate compliance with this DPA. The Processor shall cooperate with audits or inspections conducted by the Controller or a qualified third-party auditor appointed by the Controller, subject to reasonable advance notice of no less than thirty (30) days, agreement on the scope and timing of the audit, and the auditor executing a confidentiality agreement acceptable to the Processor.

13.2 Costs

Audits shall be conducted at the Controller's expense and shall be carried out in a manner that does not unreasonably disrupt the Processor's operations.

13.3 Regulatory Cooperation

The Processor shall cooperate with any supervisory authority having jurisdiction over the processing of Personal Data subject to this DPA, to the extent required by applicable law.
14

Liability and Indemnification

14.1 Processor Liability

The Processor shall be liable to the Controller for damages caused by processing that is not in compliance with this DPA or applicable Data Protection Law, where the Processor has failed to comply with its obligations under this DPA or has acted outside or contrary to the Controller's lawful instructions.

14.2 Controller Liability

The Controller shall be liable for any damages arising from its failure to comply with applicable Data Protection Law, including its failure to provide a valid legal basis for processing, its submission of Personal Data in violation of applicable law, or its failure to fulfill its obligations under this DPA.

14.3 Limitation

Each party's liability under this DPA shall be subject to the limitations and exclusions of liability set out in the Agreement to the fullest extent permitted by applicable law. Nothing in this DPA limits either party's liability to Data Subjects or supervisory authorities under applicable Data Protection Law.
15

Term and Termination

This DPA shall remain in effect for the duration of the Agreement. Upon termination or expiry of the Agreement for any reason, this DPA shall automatically terminate, subject to the survival of those provisions that by their nature should survive, including Sections 10, 11, 12, and 14.

16

Governing Law

This DPA shall be governed by the laws specified in the Agreement. For the avoidance of doubt, where the SCCs apply pursuant to Section 7, the governing law and jurisdiction provisions of the applicable SCCs shall take precedence with respect to matters governed by those clauses.

17

Entire Agreement; Order of Precedence

This DPA, together with the Agreement and any applicable SCCs, constitutes the entire agreement between the parties with respect to the processing of Personal Data. In the event of any conflict, the order of precedence shall be: first, the applicable SCCs; second, this DPA; third, the SaaS Agreement and applicable Order Form; fourth, the Terms of Use and User Agreement; and fifth, the Privacy Policy.

A·I

Annex I Details of Processing

A. List of Parties

ControllerProcessor
NameCustomer (as identified in the Agreement)Engineersmind Corp
AddressAs set out in the AgreementJersey City, New Jersey, United States
ContactAs set out in the AgreementSupport@pdffillr.ai
RoleControllerProcessor

B. Description of Processing

ItemDescription
Subject matterAutomated document analysis, AI-powered PDF form population, file storage, and related services provided through the PDFFillr platform.
Nature and purposeProcessing of Personal Data contained in documents uploaded or generated by the Controller for the purpose of delivering the Services as described in the Agreement.
DurationFor the term of the Agreement and until deletion or return in accordance with Section 10.
Categories of Data SubjectsThe Controller's customers, clients, employees, contractors, end users, and other individuals whose Personal Data is contained in documents submitted through the Services.
Categories of Personal DataContact information; government-issued identification data; financial account and transaction data; health and medical information; employment and professional information; and other Personal Data contained in documents submitted by the Controller.
Sensitive Personal DataThe parties acknowledge that documents submitted may contain health data, financial account data, and government-issued identification numbers, which are treated as sensitive categories under applicable law.
A·II

Annex II Technical and Organizational Security Measures

The Processor's technical and organizational security measures include:

  • Encryption of Personal Data in transit using TLS and at rest using AES-256 or equivalent;
  • Role-based access controls with least-privilege principles;
  • Multi-factor authentication for personnel accessing production systems;
  • Security logging, monitoring, and alerting;
  • Regular vulnerability assessments and patch management;
  • Incident response procedures with defined escalation and notification timelines;
  • Sub-processor security assessment and contractual obligations;
  • Data minimization and purpose limitation practices.
A·III

Annex III Sub-Processors

Sub-processorEntity LocationProcessing LocationPurpose
Amazon Web Services, Inc. (AWS Bedrock)United StatesUnited StatesAI model processing and cloud infrastructure hosting
Anthropic, PBC (Claude)United StatesUnited StatesAI model inference and document processing
OpenAI, LLCUnited StatesUnited StatesAI model inference and document processing
Google LLC (Google Drive)United StatesUnited StatesDocument storage and file integration
Dropbox, Inc.United StatesUnited StatesDocument storage and file integration

The Processor shall maintain and make available an updated sub-processor list upon request at Support@pdffillr.ai.

By accessing or using the Services, the Customer agrees to the terms of this Data Processing Addendum.

Effective DateApril 8, 2026
Last UpdatedApril 8, 2026