Data Processing Agreement

Last updated: October 24, 2026

This Data Processing Agreement ("DPA") forms part of the Terms of Use between Feelim ("Feelim", "we", "us") and the customer who accepts them ("Customer", "you"). It applies when you use the Service to create, schedule or publish content for your own clients or for other people, and that content contains personal data that Feelim processes on your behalf. It applies automatically when you accept the Terms; no separate signature is needed. If your organization requires a signed copy, write to report@feelim.io.

1. Roles and scope

For the personal data contained in the content you enter, upload, generate, schedule or publish through the Service ("Customer Personal Data"), you are the controller (or, if you act for your own client, a processor on behalf of your client) and Feelim is the processor (or sub-processor). In Colombian law terms, you are the "Responsable del Tratamiento" and Feelim is the "Encargado del Tratamiento". For the data we use for our own purposes, such as your account and billing data, Feelim is an independent controller under our Privacy Policy.

This DPA covers the GDPR (EU and UK), Colombian Law 1581 of 2012 and its regulations, and US state privacy laws such as the CCPA/CPRA ("Data Protection Laws").

2. Details of the processing

ItemDescription
Subject matter and purposeProviding the Service: storing drafts, generating text and images with AI, scheduling and publishing content to LinkedIn, and storing brand assets
DurationWhile your account is active, plus the deletion period in section 3
Nature of processingHosting, storage, transmission to AI model providers and to LinkedIn, generation, formatting and deletion
Types of personal dataNames, job titles, images, videos, voice and other personal data that appears in the texts, documents, images and videos you provide; LinkedIn identifiers and access tokens of the accounts you connect; brand names and logos
Data subjectsYour clients and their employees, people who appear in your content, and the audience mentioned in it
Special categories of dataNot intended. You must not submit sensitive data (see the Acceptable Use Policy)

3. Our obligations

  • Instructions. We process Customer Personal Data only on your documented instructions, which are the Terms, this DPA and your use of the features of the Service, unless the law requires otherwise. We tell you if we believe an instruction breaks Data Protection Laws.
  • Confidentiality. People who access Customer Personal Data are bound by confidentiality and limited to those who need access to provide the Service.
  • Security. We apply technical and organizational measures appropriate to the risk, including encryption in transit and encryption at rest provided by Microsoft Azure, user authentication through Microsoft Entra External ID, separation of data by account, limited staff access, and usage limits against abuse.
  • Assistance. We help you, taking into account the nature of the processing, to answer requests from data subjects, and to meet your security, breach notification and impact assessment duties.
  • Personal data breaches. We notify you without undue delay after becoming aware of a breach affecting Customer Personal Data, with the information we have to help you meet your own notification duties.
  • Deletion and return. You can delete drafts and content in the app. When your account ends, or on your request, we delete Customer Personal Data from our active systems within 30 days at most, unless the law requires us to keep it. Content already published on LinkedIn is controlled by LinkedIn and your accounts there.
  • Audits. We make available the information needed to show compliance with this DPA and allow reasonable audits, no more than once a year unless a breach requires otherwise, with reasonable notice, during business hours and under confidentiality. The Customer bears the cost of audits.

4. Sub-processors

You authorize us to use the sub-processors below to provide the Service. We have written agreements with them that require data protection obligations equivalent to this DPA, and we remain responsible for them.

Sub-processorPurposeLocation
Microsoft Azure (including Azure AI Foundry and Microsoft Entra External ID)Cloud hosting, storage, sign-in, AI modelsUnited States (East US regions)
Anthropic (Claude)AI text generationUnited States
OpenAIAI text and image generationUnited States
Google (Gemini)AI text and image generationUnited States

LinkedIn is not our sub-processor: when you publish, we send your content to LinkedIn on your instruction and LinkedIn processes it under its own terms.

We give you at least 30 days' notice of a new or replacement sub-processor, by email or in the Service. You may object on reasonable data protection grounds within that period; if we cannot resolve the objection, you may stop using the affected feature or end the Service and cancel your plan, subject to the Terms.

5. International transfers

We and our sub-processors process data in the United States and in Colombia, outside the EEA, UK and Switzerland. Where Customer Personal Data subject to the GDPR is transferred to a country without an adequacy decision, the parties agree to the Standard Contractual Clauses adopted by the European Commission (Decision 2021/914), Module Two (controller to processor) or Module Three (processor to processor) as applicable, which are incorporated into this DPA, together with the UK International Data Transfer Addendum and the Swiss amendments where they apply. In case of conflict the Clauses prevail. For data of Colombian origin, the transfer is made on your instruction and under the safeguards required by Colombian law.

6. Your obligations

  • You are responsible for the lawfulness of the Customer Personal Data and of your instructions, including having the authority of your clients and a valid legal basis, and giving the required notices and obtaining the required consents from data subjects.
  • You must have a written agreement with your own clients that allows you to use Feelim and its sub-processors for them.
  • You must not submit sensitive personal data, and you must use the Service according to the Acceptable Use Policy.

7. US state privacy laws

For personal information subject to the CCPA/CPRA or similar laws, Feelim is your "service provider" or "processor". We will not sell or share the information, retain, use or disclose it outside the direct business relationship or for purposes other than providing the Service, or combine it with other information, except as the law allows. We will tell you if we can no longer meet our obligations under those laws, and you may take reasonable steps to stop and remediate unauthorized use.

8. Colombia

As Encargado del Tratamiento, Feelim processes Customer Personal Data according to the instructions and the data policy of the Responsable, keeps it secure, does not use it for other purposes, and helps the Responsable to answer queries and claims of data holders within the legal periods. You, as Responsable, are responsible for obtaining the authorization of data holders.

9. Liability and order of precedence

Each party's liability under this DPA is subject to the limitations and exclusions in the Terms, to the extent the law allows, and without limiting the rights of data subjects. If this DPA conflicts with the Terms on data protection, this DPA prevails. The Standard Contractual Clauses prevail over both.

10. Contact and changes

For questions, to request a signed copy or to exercise your rights under this DPA, write to report@feelim.io. We may update this DPA, for example to reflect changes in law or sub-processors; the date at the top shows the latest version, and material changes are notified to you in advance.