Legal

Data Processing Agreement

Processor terms for end-customer enquiries handled on behalf of a subscribing venue.

Last updated 4 October 2026. This page sets out the processor terms that apply to every subscription. The processor is Padmina Ltd (company number 17211829, registered office 71-75 Shelton Street, Covent Garden, London WC2H 9JQ). To execute a countersigned copy, email admin@padmina.co.uk.

Roles

For end-customer personal data (people who message your venue), the venue is the data controller and Padmina is the data processor. We process this data only on the venue's documented instructions, as set out in our Terms of Service and the venue configuration in the Padmina dashboard.

Categories of personal data

End-customer name, contact handle (email / phone / social), and any other identifiers they provide.
Conversation content: what the customer wrote, what Padmina replied.
Enquiry metadata: channel, timestamps, status, lead score.

Sub-processors

We use a small number of sub-processors to deliver the service. Each is bound by contractual terms that prohibit use of your data to train their models. Current list:

Hostinger International Ltd — server hosting (United Kingdom / EU).
Google LLC — Gemini API (AI responses, Paid Services tier) and Google Calendar API (availability, read-only, where the venue connects a Google calendar).
Microsoft Corporation — Azure Speech (text-to-speech for phone calls, processed in the EU — Sweden Central region) and Microsoft Graph (availability, read-only, where the venue connects an Outlook calendar).
OpenAI, L.L.C. — fallback AI model when the primary provider is unavailable.
Groq, Inc. — speech-to-text for phone calls (caller audio only; Zero Data Retention enabled).
Meta Platforms, Inc. — WhatsApp, Instagram and Messenger delivery.
Twilio Inc. — telephony for the phone line.

We will give 30 days' notice before adding a new sub-processor and will obtain equivalent contractual protections from each.

Security

We implement appropriate technical and organisational measures including encryption in transit and at rest, role-based access, audit logging, isolated storage per venue, and regular backup with encrypted off-site copies. Specific controls available on request under NDA.

Data subject rights

If an end-customer asks us directly for access, deletion, or correction of their data we will refer them to the venue and assist the venue in responding within statutory timescales.

Breach notification

We will notify the venue without undue delay (and in any event within 72 hours) of becoming aware of a personal data breach affecting their customers, providing the information required for the venue's own ICO notification.

Retention and deletion

On termination we will delete or return the venue's customer data within 30 days, except where UK law requires us to retain it.

International transfers

Some sub-processors process personal data outside the UK and EEA — currently this includes our AI model provider for inference. These transfers are safeguarded by the UK Addendum to the EU Standard Contractual Clauses, supported by a Transfer Risk Assessment, and constrained by a written sub-processor agreement. A current list of which sub-processors operate where is available on request. We will not add a new international sub-processor without first updating this section and giving the 30 days' notice described above.

Contact

To request a counter-signed DPA, raise a sub-processor objection, or for any other processor-related question: admin@padmina.co.uk.