Data Processing Agreement

Version: 1.6
This English version is provided for convenience. The German version controls.

1. Parties and scope

This Article 28 GDPR Data Processing Agreement ("DPA") is between the business customer named in the electronic acceptance record ("Customer") and V-IZ Video-Integrationszentrum, sole proprietor Fuat Karacocuk, operating under the Doli product name, S 3, 2A, 68161 Mannheim, Germany, info@doliapp.de, VAT ID DE446446262 ("Doli"). It applies only to Doli business accounts and instructed processing described in Annex 1.

2. Priority and definitions

This DPA supplements the Business Terms and prevails for conflicts concerning personal-data processing. GDPR terms retain their statutory meaning. "Customer Data" means personal data Doli processes on behalf of the Customer. "Applicable Data Protection Law" means mandatory privacy law applicable to the relevant processing.

3. Customer role and Doli roles

The Customer selects whether it is a controller or processor. A processor Customer acts for one or more upstream controllers and engages Doli as a further processor.

Doli is a processor/subprocessor for customer-directed audio, text, chat, subtitles, images, PDFs, document content, response wishes, generated translations or explanations, and routing data strictly necessary for that content. Doli is an independent controller for account and authentication, business profile and representative, role selection, acceptance and evidence, web or earlier Store purchase, entitlement, allowance, reconciliation, accounting, legal defense, and Doli's own support, security, fraud, abuse, and reliability data.

4. Subject matter, duration, nature and purpose

The subject matter is Doli's real-time interpretation, chat and subtitle translation, and camera, image, PDF, and document explanation including reply suggestions. Instructed processing begins only with an activated business contract and ends with the service unless earlier deletion or mandatory retention applies. Annex 1 defines purposes, data, data subjects, and deletion criteria.

5. Instructions and purpose limitation

Doli processes Customer Data only on documented instructions unless Union or Member State law requires otherwise and gives prior notice where permitted. The Business Terms, this DPA, its Annexes, account configuration, and lawful feature use are initial documented instructions.

Zero data retention applies to the project identified in Annex 1 as defined by Google: the exception from Vertex abuse-monitoring prompt logging is approved, the project's data cache is disabled, and Doli uses no storing Google features. Lawful use within that scope constitutes the documented instruction. If any of these conditions ceases to apply, Doli informs the controller without undue delay. Doli does not promise exclusively European processing of all providers' account, billing and technical service data. Further instructions must be in text form. Doli promptly reports an instruction it believes unlawful and may suspend it while the parties clarify it.

6. Customer obligations

The Customer ensures a lawful basis, transparency, lawful transfer, protected devices, and access only by authorized adults. Special-category data may be submitted only with a lawful basis, necessity, and appropriate safeguards.

A processor Customer warrants that each relevant upstream controller has authorized the instructions, Doli, and Doli's content subprocessors. It forwards notices about incidents, subprocessors, unlawful instructions, data-subject requests, audits, and transfers without undue delay. Upstream controller identity is not collected by default; the Customer provides it to info@doliapp.de when required for a record, notice, audit, or request.

7. Confidentiality and security

Doli ensures authorized persons are bound by confidentiality or an appropriate statutory duty and receive only necessary access. Doli maintains Annex 2's technical and organizational measures. Measures may evolve if the agreed overall level of protection is not materially reduced.

8. Subprocessors

The Customer gives general written authorization for Annex 3's direct subprocessors. Doli flows down Article 28 obligations and remains fully liable to the Customer for performance of its subprocessors' obligations. Doli gives at least 30 days' notice of a new or replacement direct subprocessor. The Customer may object on documented privacy grounds and may terminate the affected service when the change takes effect if no reasonable solution exists.

9. International transfers

Restricted transfers occur only on documented instructions, as required for the agreed service, and under applicable transfer law. Annex 4 applies based on the server-enabled Customer country and actual transfer. SCCs or regional addenda are incorporated only when the concrete transfer requires them.

10. Assistance and data-subject rights

Doli assists, taking account of the processing nature, with data-subject rights, security, impact assessments, and authority consultation to the extent the processing concerns Doli and information is available. Doli forwards permissible Customer Data requests and does not answer independently without instructions.

Extraordinary assistance beyond the regular service may be charged reasonably only after advance cost information. No charge applies where Doli's or its subprocessor's breach caused the work.

11. Personal-data breaches

Doli notifies the Customer without undue delay when Doli becomes aware of a Customer Data breach and does not wait for internal confirmation. As available, the notice states the nature, categories and approximate numbers of affected people and records, contact point, likely consequences, and remedial or mitigation measures. Missing information follows in phases.

12. Return and deletion

At service end, Doli returns or deletes Customer Data at the Customer's choice and deletes remaining copies unless mandatory law requires retention. Mandatorily retained data is restricted, purpose-limited, and deleted when the period ends. Doli passes valid deletion instructions to affected subprocessors.

13. Evidence and audits

Doli first provides current security documentation, agreements, TOMs, certificates, provider reports, and reasonable questionnaires. If those are reasonably insufficient, the Customer may conduct one reasonable audit per twelve-month period. Additional audits are permitted after an incident or on competent-authority order. Audits use reasonable notice, business hours, confidentiality, and minimal disruption. The Customer bears its costs unless a material Doli-attributable breach is found.

14. Provider safety and policy processing

Since 25 September 2026, Doli processes all content through Google Cloud Vertex AI: spoken translation and the language request at start with Gemini 3.8 Live, chat, captions and letter and image explanations with Google's Gemini Flash models. The model location is set to the Google Cloud EU multi-region for all of these features; in normal operation they all use the EU endpoint of the Vertex API. The same route serves personal and business accounts; there is no longer a commitment to Germany. The Gemini Developer API of Google LLC is no longer used.

For captions, Doli's relay splits the microphone signal by loudness into speech segments and sends each segment as a short audio file inline in the request to a Gemini Flash model; neither the File API nor Google Cloud Storage is used for this. The relay only detects pauses in speech; it identifies no persons and creates no voice profiles. The segments stay only in memory until the translation returns (at most 12 seconds) and are not stored. As a fallback, captions can temporarily run on Gemini 3.5 Live Translate. The relay then streams the microphone signal continuously through the global Vertex endpoint, because Google does not offer this model on the EU endpoint; the model location remains the EU multi-region. In both cases the same subprocessor processes the same data types for the same purpose.

Google processes Vertex Customer Data as a subprocessor under its Cloud Data Processing Addendum. Zero data retention applies to Google Cloud project 674711097607 as defined by Google: Google approved the requested exception from abuse-monitoring prompt logging, the project's data cache is disabled, and Doli uses no feature under which Google stores content. Google therefore processes conversation content only for the respective request and stores it neither for abuse review nor in a cache. Automated safety checks during processing remain in place. If any of these conditions changes, Doli updates this notice.

Google does not use Vertex Customer Data to train or fine-tune AI models without prior permission or instruction. Doli gives no such permission for conversation content. Doli does not sell content or use it for advertising or profiling.

Doli does not use session resumption, search or maps grounding, stored interactions or explicit context caching. Google's in-memory cache is disabled for the Doli project.

Doli gives no professional-secrecy commitment under section 203 of the German Criminal Code. No separate agreement of that kind forms part of this service. Annexes 1 and 3 provide further details.

15. Electronic acceptance and activation

For a new business agreement through the website, the displayed web terms and, where applicable, the pay-as-you-go addendum govern formation and technical activation. The representative must have authority to bind the Customer. A browser display or redirect is not sufficient technical evidence of activation.

Earlier native business purchases remain governed by the Apple App Store or Google Play and RevenueCat activation route identified in their acceptance record. New business plans are concluded exclusively through the website.

After activation, the Customer receives a personalized immutable contract copy with party and representative details, role, document versions and hashes, acceptance and activation times and a non-sensitive purchase or setup reference.

16. Term, amendments and final provisions

This DPA applies for instructed processing. Amendments require at least text form; mandatory data-subject and authority rights remain unaffected. German law applies. Principal-agreement jurisdiction applies only where lawful. Invalidity of one term does not affect the remainder.

Annexes: (1) Processing Details, (2) Technical and Organizational Measures, (3) Provider and Role Schedule, and (4) International Schedules.