Terms clause — strict disconnected on-premise

Article X — Mode of operation: strict disconnected on-premise

X.1 — Distribution as software. Natalia SAS distributes the Natalia Analytics appliance (the « Software ») as a virtual machine image deployed by the Customer on its own infrastructure. The Software is operated by the Customer for its own account and under its sole responsibility.

X.2 — Strict disconnected mode. In strict disconnected mode, the Software performs no outbound network connection towards Natalia, except for the licence verification channel described in Article X.4. In particular, the Software transmits to Natalia no Call Detail Record (CDR), no phone number, no call content, no user account, no aggregated KPI and no audit log.

X.3 — Legal qualification. The Parties acknowledge that, in strict disconnected mode, Natalia acts as a publisher of standard software within the meaning of GDPR Recital 26 and EDPB Guidelines 07/2020 §28-29. Natalia is neither a controller nor a processor of the personal data processed by the Software. Consequently, no Data Processing Agreement (DPA) is signed for this mode, and no sub-processor of Natalia processes the Customer's personal data.

X.4 — Licence channel. The Software periodically verifies the validity of the licence with Natalia. This verification carries only (i) the Customer organisation identifier (UUID assigned to a legal entity), (ii) a signed licence token, and (iii) an anonymous heartbeat (counter of internal errors, appliance version, hardware fingerprint hash). The source IP address of the Customer's appliance is recorded by Natalia for anti-fraud purposes on the basis of legitimate interest (art.6-1-f GDPR), anonymised after 30 days, and deleted within 13 months at the latest. The Customer's rights are exercised with the Natalia DPO at [email protected].

X.5 — Sub-processors. In strict disconnected mode, Natalia engages no sub-processor that processes Customer personal data. The infrastructure used to operate the licence channel is qualified as an operational tool of Natalia, not as a downstream sub-processor of the Customer.

X.6 — Switch to connected mode. The Customer may activate connected mode in the admin UI of the Software. This activation is subject to the prior signature of the DPA referenced in Article X.7 and triggers the change of legal qualification described in that DPA.

X.7 — Reference documents. The Parties refer to the on-premise GDPR page (https://getnatalia.com/en/legal/rgpd-on-premise) for the detailed legal qualification, and to the connected mode DPA (https://getnatalia.com/en/legal/dpa/dpa-connected) in case of switch to connected mode.