Data Processing Agreement (DPA)

Last Updated: January 9, 2025

This Data Processing Agreement ("Agreement") forms part of the Terms of Service between Pinocch AI ("Pinocch", "we", "us", or "our") and you ("User", "you", or "your") governing your use of the AiParse Service ("Service"). This Agreement outlines the obligations of both parties concerning the processing of data submitted through the AiParse API.


1. Purpose

The purpose of this Agreement is to ensure that the processing of data submitted to the AiParse Service is conducted in compliance with applicable data protection laws and regulations, while clearly defining the roles and responsibilities of Pinocch and its third-party service providers.


2. User Consent for Data Processing

By using the AiParse Service and agreeing to these Terms and Additional Terms, you explicitly consent to Pinocch AI processing your personal data for the purposes outlined in our Privacy Policy. This includes:

For processing involving sensitive information, we will ensure a lawful basis for processing, including obtaining your explicit consent where required by applicable law. You have the right to withdraw your consent at any time, subject to contractual or legal restrictions. Refer to our Privacy Policy for details on how to withdraw your consent.


3. Data Minimization and User Responsibility

Pinocch AI is committed to the principle of data minimization. The AiParse Service is designed to process PDF documents for text extraction and structuring into JSON or Markdown formats. We strongly advise users not to upload documents containing sensitive personal data or personally identifiable information (PII) to the Service.


4. Responsibilities of Pinocch AI as the Data Controller

As the Data Controller, Pinocch AI is responsible for:


5. Third-Party Providers

We engage reputable third-party AI service providers (including OpenAI, Anthropic, Google Cloud Platform, Amazon Web Services) to assist in the provision of the AiParse Service. These service providers adhere to their own data protection policies as outlined in their respective terms and conditions on their official websites.


6. Subject Matter and Duration of Processing


7. Types of Data Processed

The AiParse Service is designed to process the textual content of documents. While we do not target or intentionally collect personal identifiable data, the types of data processed may include any information contained within the PDF documents uploaded by users.


8. Disclaimer Regarding Personal Data

Pinocch AI strongly discourages users from uploading documents containing personal identifiable data or sensitive information. While we implement industry-standard security measures, we cannot guarantee the absolute security of data transmitted over the internet or processed by third-party services.

Pinocch AI shall not be held liable for any damages, losses, or liabilities arising from the unauthorized access, use, or disclosure of personal data contained in documents uploaded by users, provided that Pinocch AI has complied with its obligations under this Agreement and applicable data protection laws.


9. Categories of Data Subjects

The data subjects are the individuals (if any) whose data may be contained within the documents uploaded by our users.


10. Data Processor Obligations

Third-party providers are obligated to maintain confidentiality, implement appropriate security measures, provide data breach notifications, and assist with data subject rights requests. These obligations are detailed in the Data Processing Agreements (DPAs) established with each provider.


11. Sub-processing

The conditions under which third-party providers may engage sub-processors are outlined in their respective DPAs. Generally, sub-processors may only be engaged with the prior written consent of Pinocch AI and must be subject to equivalent data protection obligations.


12. Audits and Inspections

We reserve the right to audit the data processing activities of third-party providers to ensure compliance with the DPAs and applicable data protection laws.


13. Governing Law

This Agreement shall be governed by and construed in accordance with the laws of Hong Kong, without regard to its conflict of laws principles.


14. Amendments

Pinocch AI reserves the right to modify this Agreement at any time. We will notify users of any material changes to this Agreement. Continued use of the Service after such notification constitutes acceptance of the modified Agreement.


15. Contact Information

If you have any questions about this Data Processing Agreement, please contact us at service@pinocch.com.