Data Processing Agreement

B3dmar ApS, trading as 3ngram ("we," "us," "our"), processes personal data on behalf of its customers under a Data Processing Agreement (DPA) within the meaning of Article 28 of the GDPR. Where you use 3ngram to store and process the personal data of your own users or contacts, you are the data controller and we act as your data processor.

Scope

The DPA governs our processing of personal data contained in the content you submit to the platform — memories, commitments, decisions, blockers, facts, preferences, patterns, notes, context, and indexed documents — for the sole purpose of providing the service described in our Privacy Policy and Terms of Service. We process this data only on your documented instructions and do not use it to train any AI models.

Sub-processors

We engage sub-processors to deliver the service — database hosting, embeddings, transactional email, subscription payments, error monitoring, and platform hosting. Each is bound by a written data processing agreement with terms no less protective than this DPA. See the sub-processors page for our approach and how to obtain the current named list.

International transfers

Personal data is primarily stored within the European Economic Area. Where processing involves a transfer to a US-based sub-processor, that transfer is protected by EU Standard Contractual Clauses (SCCs) incorporated into the DPA.

Security, breach notification, and assistance

The DPA sets out the technical and organisational measures we maintain to protect personal data (consistent with our security practices), our obligations to assist you with data-subject requests and impact assessments, and our commitment to notify you without undue delay on becoming aware of a personal data breach.

Requesting the DPA

To request a counter-signable copy of our current Data Processing Agreement, including the named sub-processor list, email legal@3ngram.ai. We will reply with a counter-signable PDF.

See also our Privacy Policy, Terms of Service, and sub-processors.