Annex to the data processing agreement: portfolio company documents with AI
Version 1.0, of October 31, 2026.
This annex supplements the data processing agreement (clause 11.4) for the AI reading of portfolio company documents. It applies to the organization whose owner accepts the prior notice of this feature in the panel. In this annex, "the Controller" is the Customer.
AI processing
(a) The Processor applies automatic pseudonymization to the identifiers of natural persons before transmitting the text to the AI sub-processor, without guaranteeing that all of them are detected.
(b) Economic and business data are transmitted without pseudonymization.
(c) Processing by the AI sub-processor takes place outside the EEA, with the safeguards of Chapter V of the GDPR.
(d) The Controller has received this notice in writing before uploading any document.
(e) If the Controller requests it in writing before uploading documents, the parties will agree on processing in the European Union through Amazon Bedrock.
(f) The Controller warrants that it has permission to upload each document, that it does not include information on listed issuers or inside information, and that it does not include data under GDPR arts. 9 and 10 unless the Controller demonstrates a legal basis.