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Data Processing Addendum

Last updated 5 November 2026

This addendum (the "DPA") forms part of the agreement between ArtemisTech LTD ("MeaningFuel", "we", "us") and the customer under our terms of service. It applies wherever we process personal data as the customer's processor, for as long as we do, and where it conflicts with the terms on personal data, it applies. Anything under it goes to privacy@meaningfuel.io.

1. Definitions

"Data protection law" means the law that applies to the personal data processed under this DPA, including the UK GDPR and the Data Protection Act 2018, and the EU GDPR where it applies. "Controller", "processor", "personal data", "processing", "personal data breach" and "data subject" have the meanings that law gives them. "Workforce data" means the personal data described in Annex A. "Subprocessor" means a third party we engage to process workforce data.

2. Roles and instructions

For workforce data, the customer is the controller and we are the processor. We process workforce data only on the customer's documented instructions: the terms, this DPA, the configuration the customer sets in the service, and any further written instructions we agree, which may carry a reasonable charge if they go materially beyond what the service does. We will tell the customer if we think an instruction breaks data protection law, and may suspend it until that is resolved. If the law requires us to process beyond instructions, we will tell the customer first unless the law forbids that.

3. The customer's obligations

The customer is responsible for the lawfulness of the workforce data and its instructions: for having a lawful basis to enrol its people, for telling them what the service does with their data (our privacy notice may be used for that), for the accuracy of what it provides, and for any authorisation its law requires, including any employee representation or works council step.

4. Confidentiality

We limit access to workforce data to people who need it to provide the service, all of whom owe a duty of confidence, and we disclose it to no one else unless this DPA allows it or the law compels it.

5. Security

We maintain the measures in Annex B and keep them appropriate to the risk. We may update them, but not in a way that materially weakens the protection of workforce data.

6. Subprocessors

The customer authorises the subprocessors in Annex C and authorises us in general to engage others. Before adding or replacing one, we will give at least 14 days notice by email to the customer's account owners. If the customer reasonably objects on data protection grounds and we cannot offer a way round, it may terminate the affected subscription and we will refund prepaid fees for the period after termination.

We bind every subprocessor in writing to obligations no weaker than this DPA's and remain fully responsible for what it does with workforce data.

7. Data subject requests

If a data subject request about workforce data reaches us directly, we will pass it to the customer promptly and not answer it beyond directing the person to the customer, unless the customer instructs otherwise or the law requires more. We give the customer reasonable help to answer such requests.

A recipient who presses Unsubscribe records a vote: it is counted against the insight and topic they were sent, and the customer sees it only as a pooled count. A recipient enrolled at their own email address, by directory sync or by hand, also stops receiving that topic; a vote from a distribution list changes only the count. The customer, as controller, decides on anything further and answers the person in the time the law gives; we act on its instruction and keep the record so it stays honoured. No model ever reads a reason or a note.

As a standing instruction, we may stop sending to an address that bounces, is refused or is reported as spam. The customer is not told who made a complaint.

8. Assistance

Taking into account the nature of the processing and the information we hold, we will give the customer reasonable assistance with its obligations on security, breach notification, data protection impact assessments and prior consultation with supervisory authorities.

9. Personal data breach

If we become aware of a personal data breach affecting workforce data, we will notify the customer without undue delay, and in any event within 72 hours, with what we then know: its nature, the categories and approximate numbers of data subjects and records affected, the likely consequences, and the measures taken or proposed. We will not notify a supervisory authority or data subjects on the customer's behalf unless it asks us to or the law requires it.

10. International transfers

Workforce data is stored in the United Kingdom. Where a subprocessor processes it outside the UK or the European Economic Area, we put in place the safeguards data protection law requires: the UK International Data Transfer Agreement or Addendum, or the EU Standard Contractual Clauses, as applicable. We will not otherwise transfer workforce data to a third country except on the customer's documented instructions.

11. Audits and information

We will give the customer the information reasonably necessary to demonstrate compliance with this DPA, starting with written answers to a reasonable questionnaire. Where that is genuinely not enough, the customer, or an independent auditor who is not our competitor, may audit our processing of workforce data: at most once in 12 months except after a personal data breach, on at least 30 days written notice, in business hours, at the customer's expense, under confidentiality, and without access to another customer's data.

12. Return and deletion

The customer can export its data from the service while the subscription runs. When the agreement ends, we provide a machine-readable export on request made within 30 days, and delete all workforce data within 30 days after that window, or sooner on instruction, except what the law requires us to keep. On written request we will confirm deletion.

13. Liability

Each party's liability under this DPA is subject to section 19 of the terms. This DPA creates no third-party rights beyond those data protection law gives data subjects.

Annex A - Description of the processing

Subject matter and purpose. Delivering the service to the customer: the daily insight to the people it enrols, modules booked onto teams, and aggregate engagement reporting.

Duration. The life of the agreement, plus the deletion window in section 12.

Nature of the processing. Hosting, storage, scheduling, transmission by email and chat webhook, recording of delivery and engagement events, aggregation into reporting, and deletion.

Data subjects. The people the customer enrols to receive the daily insight, and its own account holders so far as their data is processed inside the service on its behalf.

Types of personal data. Email address; first name where given; team, manager, department and job title where provided; an identifier from the customer's directory or HR system where synced, and how the record arrived; the team's timezone, send hour and days; per-message records of delivery, failure, whether the link to the answer page was followed, quiz answers, the four-way reaction, spam complaints, and the occasional question shown and answered; bounce and refusal records; module acceptances, delivery of each day's email, answers, voluntary practice confirmations, check-in answers and notes; leader pulse scores, theme choices and notes; modules booked and weather windows, attributed to the account that made them; delivery records of the summary; alerts, which name a team and a theme and not a person; votes to stop the emails, with the insight and topic, any reason and any note; and unsubscribe records.

Further types are processed only once we offer the features that hold them, and we will update this DPA first: that a person answered a light module's closing question, and, on the live board for a module's game, each player's first name, avatar and position and what the host typed for the game.

Special categories. None. The customer agrees not to put any into free text, and not to enter a complaint, an allegation or a description of a named person's conduct.

Annex B - Technical and organisational measures

Annex C - Subprocessors

Each is bound by the EU Standard Contractual Clauses and UK Addendum in its data processing agreement, for any processing outside the UK.

PostHog (product analytics) receives no workforce data, only telemetry about account holders, for which we are the controller. Stripe, Google and Microsoft act as their own controllers. Our mailboxes are hosted by Proton AG (Switzerland, which holds UK and EU adequacy decisions), and workforce data reaches Proton only if the customer puts it in an email to us. The customer's own connected services are its providers, used on its instruction, not subprocessors.

Also see our terms of service and privacy policy.