isLUCID DATA PROCESSING SCHEDULE
Appendix No. 1 to the isLucid Data Processing Agreement (DPA) · Version 261013/0001 · Last updated: October 13, 2026
This Data Processing Schedule (hereinafter – the Schedule) forms an integral part of the isLucid Data Processing Agreement (hereinafter – the DPA), which is Annex No. 5 to the isLucid Platform Terms and Conditions (hereinafter – the Terms). The Schedule sets out the processing parameters required under Article 28(3) of Regulation (EU) 2016/679 (the GDPR) and constitutes the Data Processing Schedule referred to in the DPA. Capitalised terms not defined in this Schedule have the meanings given to them in the DPA and the Terms.
The Schedule applies to all Orders under the Terms, unless the Customer gives other documented instructions through the Platform or the Parties agree otherwise in Special Terms.
| Parameter | Content |
|---|---|
| Roles of the Parties | The Customer – Data Controller; UAB „Lucid Agreements“ – Data Processor (Clause 1 of the DPA). |
| Subject matter | Provision of the Platform and the Services ordered by the Customer under the Terms. |
| Nature of processing | Collection, transmission, storage, voice processing, transcription, automated analysis and classification, technical logging, backup, return and erasure of personal data, to the extent necessary for the ordered Services (Clause 2.2 of the DPA). |
| Purpose of processing | Execution and monitoring of the AI voice agents and Workflows configured by the Customer, including voice interactions, transcription, analytics, integrations configured by the Customer and technical support. |
| Duration of processing | The term of the relevant Order and the retention period set out below. |
| Categories of data subjects | Persons participating in calls or other interactions handled through the Platform (such as the Customer’s clients, prospective clients, candidates, partners and other contacts); the Customer’s employees and other Users; other persons whose personal data the Customer lawfully makes available through the Platform. |
| Types of personal data | Identification and contact data (e.g. name, telephone number, e-mail address); voice recordings, transcriptions and conversation content; call metadata (e.g. time, duration, call outcome); Account and User data; internal identifiers; API / MCP / tool-call data and other data which the Customer lawfully provides or makes available through the Platform. |
| Special categories of personal data | Not intended to be processed. Special categories of personal data (Article 9 of the GDPR) and data relating to criminal convictions and offences (Article 10 of the GDPR) may be processed only in accordance with Clause 2.5 of the DPA. |
| Processing location | EU / EEA (Section 6 of the DPA). |
| Retention period | As configured by the Customer on the Platform and, by default, up to 30 (thirty) days after the end of the relevant Order, subject to Clause 11.7 of the Terms and Section 9 of the DPA. Personal data in backups is deleted in accordance with Clause 9.2 of the DPA. |
| Sub-processors | As listed in Section 5 of the DPA, as updated in accordance with Clause 5.2 of the DPA. |
| International transfers | None by default. Any transfer is made only in accordance with Section 6 of the DPA. |
| Use for AI model training | Personal data is not used for the training, testing or improvement of general AI models, except as provided in Clause 1.4 of the DPA. |
| Documented instructions of the Data Controller | The Terms, the DPA, this Schedule and the configurations, settings and instructions made by the Customer through the Platform. |
This Schedule may be amended in accordance with Clause 10.2 of the DPA.