Data Processing Agreement
Last updated: November 2026
This Data Processing Agreement ("DPA") forms part of the Terms of Service between FastCork ("FastCork", "we", "Processor") and the customer using the FastCork API ("Customer", "Controller"). It applies wherever FastCork processes personal data on the Customer's behalf under the UK GDPR, the EU GDPR (Regulation 2016/679), or equivalent data protection law. By using the API, the Customer agrees to this DPA. A countersigned copy is available on request.
1. Roles and Scope
The Customer is the controller and FastCork is the processor of Customer Data. "Customer Data" means data submitted to the API: wine label images, search queries, and chat messages. FastCork processes Customer Data solely to return API responses, on the Customer's documented instructions, which consist of the API requests themselves and this DPA.
The API is designed for wine labels, not people. Customers should not submit images of individuals or include names, emails, or user identifiers in requests. Where incidental personal data is present (for example, a face in the background or location metadata embedded in a photo), it is handled under this DPA.
Account and billing data (account email, billing details) is processed by FastCork as an independent controller to operate the Customer's account, and is described in our Data Agreement.
2. Zero Data Retention
- Wine label images are processed in memory and discarded once the response is returned. They are not written to disk, databases, object storage, caches, or logs.
- Search queries are processed in memory and not stored.
- Chat sessions are stored for up to 24 hours to support multi-turn conversation, then deleted automatically. The Customer can delete a session sooner by calling
DELETE /v1/chat/:id. Images sent to chat are not stored; only a short text description of the image is kept with the session. - Operational logs record request metadata (endpoint, timing, status, error details) and may include the structured wine result returned (for example, the identified wine name). They never contain images. Logs are retained for up to 7 days for debugging, then deleted.
- Usage records are aggregated request counts per API key for billing. They contain no images, queries, or responses.
3. No Training
Customer Data is never used to train, fine-tune, evaluate, or otherwise improve any machine learning model, by FastCork or by any subprocessor.
4. Processor Obligations
FastCork will:
- process Customer Data only on the Customer's documented instructions, and inform the Customer if it believes an instruction infringes data protection law;
- ensure that anyone authorised to process Customer Data is bound by confidentiality;
- implement the security measures in Section 7;
- engage subprocessors only as described in Section 5;
- assist the Customer, taking into account the nature of the processing, in responding to data subject requests and in meeting its obligations on security, breach notification, data protection impact assessments, and prior consultation;
- delete Customer Data at the end of the service, as described in Section 9; and
- make available the information necessary to demonstrate compliance with this DPA, as described in Section 10.
5. Subprocessors
The Customer gives general authorisation for FastCork to engage the categories of subprocessors below. Each subprocessor is bound by written terms that impose data protection obligations no less protective than this DPA, including zero data retention and no training on Customer Data. FastCork remains fully liable for its subprocessors' performance.
| Subprocessor or category | Purpose | Data received | Location |
|---|---|---|---|
| Cloudflare, Inc. | Hosting, edge compute, image resizing, session storage, logging | All Customer Data, in transit and as described in Section 2 | Global edge network; request runs at a location near the caller or the inference provider |
| AI inference providers (primary and failover) | Running the vision and language models that generate responses | Images, queries, and chat messages, transiently, with zero retention | United States |
| Stripe, Inc. | Payment processing | Account and billing data only, never Customer Data | United States |
| Transactional email provider | Account and billing emails | Account email address only, never Customer Data | United States |
Named subprocessor list. Because our inference stack is commercially sensitive, the vendors in each category are not published here. Customers and prospective customers may request the full named list from support@fastcork.com, and we will supply it before the Customer submits personal data. We may ask the recipient to keep it confidential.
Changes. We will notify Customers who have requested the named list, by email, at least 30 days before adding or replacing a subprocessor that receives Customer Data. The Customer may object on reasonable data protection grounds within that period. If we cannot reasonably address the objection, the Customer may terminate the affected service and receive a refund of any prepaid, unused fees.
6. International Transfers
Customer Data is processed in the United States and on Cloudflare's global network. Where Customer Data is transferred from the UK, the EEA, or Switzerland to a country without an adequacy decision, the transfer is governed by:
- for EEA transfers, the EU Standard Contractual Clauses (Commission Decision 2021/914), Module 2 (controller to processor), which are incorporated into this DPA by reference;
- for UK transfers, the International Data Transfer Addendum to the EU Standard Contractual Clauses issued by the UK Information Commissioner, incorporated by reference; and
- for Swiss transfers, the EU Standard Contractual Clauses as amended for the Swiss Federal Act on Data Protection.
Where a subprocessor is certified under the EU-US Data Privacy Framework or its UK Extension, that certification may be relied on instead. Onward transfers to subprocessors are covered by equivalent safeguards.
7. Security
- All API traffic is encrypted in transit with TLS (HTTPS only).
- Images are held in memory only for the duration of a request.
- Infrastructure runs on Cloudflare's network with built-in DDoS protection.
- Access to production systems is limited to authorised personnel.
- Account passwords are stored as salted PBKDF2 hashes.
8. Personal Data Breaches
FastCork will notify the Customer without undue delay, and in any event within 48 hours of becoming aware of a personal data breach affecting Customer Data. The notice will include the information reasonably available to help the Customer meet its own notification obligations.
9. Deletion and Return
Because images and queries are not stored, there is nothing to return after processing. On termination, any remaining chat sessions expire within 24 hours and operational logs within 7 days. Account data is handled as described in the Data Agreement.
10. Audits
On written request, and no more than once a year unless required by a regulator or following a breach, FastCork will answer reasonable written questionnaires and provide documentation sufficient to demonstrate compliance with this DPA, including relevant subprocessor certifications.
11. Liability and Precedence
Liability under this DPA is subject to the limitations in the Terms of Service, except where data protection law does not allow it. If this DPA conflicts with the Terms of Service, this DPA prevails for the processing of personal data. If it conflicts with the Standard Contractual Clauses, the Clauses prevail.
Annex: Description of Processing
- Subject matter and purpose: wine label recognition, wine search, and AI sommelier chat via the FastCork API.
- Duration: for the term of the Customer's use of the API, with the retention periods in Section 2.
- Nature of processing: receipt, transient analysis, and return of results.
- Categories of data: wine label images, search queries, chat messages, and any personal data incidentally included in them.
- Data subjects: the Customer's end users and any individuals incidentally captured in submitted content.
- Special category data: none intended. Customers must not submit it.
Contact
DPA requests, the named subprocessor list, and data protection questions: support@fastcork.com