Data Processing Addendum
Last Updated: April 2, 2026
1 Scope and Roles
MACSEI OÜ (Cogniverse) acts as Data Processor / Service Provider. The User acts as Data Controller when inputting personal data into the Service.
2 Nature and Purpose of Processing
Solely to provide the Cogniverse Service: parsing documents and generating AI responses based on User prompts.
3 Sub-processors
| Sub-processor | Purpose |
|---|---|
| OpenAI, L.L.C. | AI Model processing |
| Google LLC | AI Model processing / Cloud Infrastructure |
| Anthropic, PBC | AI Model processing |
| Stripe, Inc. | Payment processing |
4 International Data Transfers
Transfers outside the EEA governed by Standard Contractual Clauses (SCCs) approved by the European Commission.
5 Security & Zero-Training Commitment
Appropriate technical and organizational security measures. Explicit guarantee: User Data processed through AI sub-processors is transmitted via enterprise APIs that opt-out of data usage for foundational model training.