Terms clause — on-premise connected (full art.28)
Activates Natalia\'s qualification as a full art.28 processor, documents Gemini sub-processing (Google Ireland, eu-west) and references the connected mode DPA.
Clause text
Article X — Mode of operation: on-premise connected
X.1 — Object. In connected mode, the Customer authorises Natalia SAS to perform additional processing on the Customer's aggregated CDR for the purpose of LLM-assisted conversational analysis. This activation is opt-in and is triggered from the admin UI of the Software.
X.2 — Art.28 processor qualification. In connected mode, Natalia SAS acts as a processor of the Customer within the meaning of art.28 GDPR. The full DPA (https://getnatalia.com/en/legal/dpa/dpa-connected) applies and supersedes Articles X.3 to X.6 of the strict on-premise variant of these Terms for the duration of connected mode.
X.3 — Data flows. Connected mode transmits to Natalia: (a) aggregated CDR uploaded explicitly by the Customer for analysis, (b) the prompts of the Customer\'s users to the conversational interface, and (c) the analytical outputs returned to the Customer\'s users. No call audio is processed. Hosting takes place exclusively in the European Union.
X.4 — Sub-processor — Gemini. Natalia uses Gemini (Google Ireland Limited, eu-west region) as a sub-processor for the LLM analysis step only. The Gemini contract provides for: (i) the absence of training on Customer prompts (0-day retention), (ii) the application of EU Standard Contractual Clauses, (iii) the hosting of the model in eu-west. The list of sub-processors is maintained up to date on the Natalia website and may evolve subject to a 30-day prior notice to the Customer (right to object).
X.5 — Return to strict disconnected mode. The Customer may deactivate connected mode at any time from the admin UI. Deactivation triggers (a) the cessation of new data transmission to Natalia, (b) the deletion within 30 days of CDR transmitted to Natalia, (c) the return to the legal qualification of software publisher as described in the strict on-premise variant.
X.6 — Reference DPA. The Parties acknowledge having signed the connected mode DPA prior to the activation of this mode. In case of conflict between this clause and the DPA, the DPA prevails on the matters of personal data protection.