Data Processing Terms

Roles

These terms are part of the Terms of Service between [Company legal name] (“we”) and the customer who owns a Cowboy Hub workspace (“you”).

For the personal data on and about your sites that passes through the Hub, you are the controller and we are your processor. For the account data of the people who use the Hub, we are the controller; the Privacy Policy covers that.

Subject matter, duration, nature and purpose

• Subject matter: providing the Hub to your workspace.
• Duration: as long as the workspace exists, and until its data is deleted afterwards.
• Nature: reading and changing your sites through the Cowboy MCP plugin and, where you add it, over SSH or SFTP; keeping the activity timeline, agent conversations, job results and restore copies; sending data to the model provider your workspace chooses.
• Purpose: carrying out the calls, skills and changes you and your members ask for, and keeping the safeguards that go with them.

Categories of data and data subjects

Data subjects are the people whose data is on your sites or about them:

• your sites’ users, customers, commenters and visitors;
• your sites’ administrators and editors;
• people named in your sites’ content.

The categories of personal data are what your sites hold and what the AI reads or changes, for example:

• user accounts: names, usernames, email addresses, roles;
• customer data and orders, comments and form entries, where a site has them;
• names and other personal data inside posts, pages and files;
• administrators’ email addresses and usernames in logs and in the activity timeline.

The Hub does not ask for special categories of data. If your sites hold them, you decide whether the Hub may work on those sites.

Processing on your instructions

We process the data only on your documented instructions. Your instructions are your use of the Hub: the sites you connect, the policies you set, the calls, skills and messages you and your members send, and the changes you approve. We do not use the data for our own purposes. If we think an instruction breaks data protection law, we tell you. If the law requires us to process the data in another way, we tell you first, unless that law forbids it.

Confidentiality

Everyone at [Company legal name] who can access the data is bound to keep it confidential, and accesses it only when needed to run the Hub, to support you on your request, or to deal with a security incident.

Security measures

We protect the data with the technical and organisational measures described on the Security page, including envelope encryption of tokens and credentials, row-level security between workspaces, and data storage in the US. We may improve these measures; we will not weaken them below that level.

Sub-processors

You allow us to use the sub-processors below. This is the same list as in the Privacy Policy. Each one is bound by data protection terms that are at least as protective as these.

We tell workspace owners by email at least [30] days before we add or replace a sub-processor. You can object in that time on reasonable data protection grounds. If we cannot resolve the objection, you can cancel your subscription before the change takes effect.

Assistance

• Data subject requests: if a person asks us about data on your sites, we pass the request to you and do not answer it ourselves. We help you answer requests where the data is in the Hub, for example the activity timeline or restore copies.
• Impact assessments: we give you the information you reasonably need for a data protection impact assessment or a consultation with a supervisory authority about your use of the Hub.

Personal data breaches

If we become aware of a personal data breach affecting your data, we tell the workspace owners without undue delay, and within [48] hours. We say what happened, what data is affected, what we have done and what you can do, and we send more detail as we learn it.

Deletion or return at the end

When the workspace ends, you can ask for an export of its data. We then delete the data within [30] days, unless the law requires us to keep it. Activity, agent conversations and job results are deleted after 90 days, and restore copies after 30 days, during the workspace’s life too.

Audits

We show that we meet these terms by documentation: this page, the Security page, and answers to reasonable security questionnaires, once a year or after a breach. Where the law requires an inspection beyond that, we agree its scope, timing and cost with you in advance. [Audit terms: confirm.]

International transfers

The Hub stores data in the US (Northern California). Where personal data from the EU or the EEA is transferred to the US, the transfer is covered by the EU Standard Contractual Clauses or another transfer mechanism the law allows.

Liability

Liability under these terms is subject to the limits in the Terms of Service.

Contact

Questions about these terms: hub@cowboymcp.com.