Data Processing Agreement
Data Processing Agreement
Effective 2026-08-12
This Agreement is entered into between Bellential Inc. (the "Processor") and the organization that uses the Service (the "Controller"). It is incorporated into the Terms of Use and takes effect when the organization confirms it while creating an organization or starting a paid seat. No separate signature is required.
The organization decides why and how its customers' personal information is processed; we process it only on the organization's instructions. Schedule 1 sets out what we process, and Schedule 2 lists every sub-processor. Both are generated from the same source as the Privacy Policy, so they cannot drift apart.
1.Article 1 (Purpose and scope)
This Agreement governs the processing of personal information that the Controller entrusts to the Processor in connection with the Service, in accordance with Article 26 of the Personal Information Protection Act.
This Agreement forms part of the Terms of Use. Where this Agreement and the Terms of Use conflict on the entrusted processing, this Agreement prevails.
The Controller is the organization. Its customers, and its members, are the data subjects.
2.Article 2 (Entrusted work)
The items, purposes, data subjects, and retention periods of the entrusted processing are set out in Schedule 1.
The Processor performs only the work described there, and processes personal information only to the extent that work requires.
Schedule 1 · What we process
Every value below comes from the same configuration the product runs on.
| Item | Detail |
|---|---|
| Items processed | Face photos, facial measurements (eyelid, nose, and contour coordinates and the millimetre values computed from them), generated results, consultation records |
| Purpose | Generating a simulation for the photo and measuring the result |
| Data subjects | The organization's customers, and the organization's members |
| Retention | Default region 3 years · United States 6 years · maximum 10 years |
| Notice on termination | On downgrade or termination, 90 days' notice before the retained material is destroyed |
3.Article 3 (Duties of the Processor)
The Processor must not process the entrusted personal information beyond the purpose in Schedule 1, and must follow the Controller's documented instructions.
The Processor applies the technical and organizational safeguards described in the Security page, including encryption in transit and at rest, access control, and an append-only audit record of access to personal information.
The Processor limits access to the personnel who need it for the entrusted work, and binds them to confidentiality that survives the end of their engagement.
The Processor does not use the entrusted personal information, or anything derived from it, to train AI models. This mirrors section 5 of the Privacy Policy and applies to organization material without exception.
4.Article 4 (Sub-processing)
The Controller agrees in advance to the sub-processors listed in Schedule 2. The Processor imposes on each of them obligations no less protective than this Agreement.
If the Processor intends to add or replace a sub-processor, it announces the change before it takes effect. An organization that objects may terminate the affected Service for the remainder of its term.
Schedule 2 · Sub-processors
This is the same list as the processor table in the Privacy Policy, drawn from the same source. If a sub-processor changes, both change together.
| Processor | Country | Data received | Entrusted work |
|---|---|---|---|
| Google Cloud / Vertex AI | United States and others | Photos, generated results, images attached in conversation | Photo and result storage, compute, simulation generation, image analysis |
| Anthropic | United States | Conversation text, task status, images attached in conversation | Assistant conversations |
| OpenAI | United States | Conversation text, images | Image blending, assistant conversations |
| fal.ai | United States | Photos, generated results | Motion video generation |
| Cloudflare | United States and others | Photos, access records | App hosting, delivery, edge processing |
| Resend | United States | Email address | Email delivery |
| Stripe | United States | Payment details, email address | Payment processing |
5.Article 5 (Cross-border transfer)
Every sub-processor in Schedule 2 is located outside Korea, so performing the entrusted work transfers personal information abroad. The recipients, countries, items, and purposes are exactly as set out in that Schedule.
The transfer occurs when the Service processes the material, over an encrypted connection, and the recipient retains it for the period stated in Schedule 1.
6.Article 6 (Assisting with data-subject rights)
Where a data subject exercises a right against the Controller, the Processor assists the Controller in responding, taking into account the nature of the processing and the information available to it.
If a data subject contacts the Processor directly about material entrusted by an organization, the Processor directs them to the Controller and notifies the Controller.
7.Article 7 (Breach notification)
If the Processor learns that entrusted personal information has been exposed, it notifies the Controller without undue delay, describing what was exposed, when and how, and what is being done about it.
Notification to data subjects and to the supervisory authority is the Controller's responsibility. The Processor provides the information the Controller needs to make it.
8.Article 8 (Inspection)
The Controller may request the documentation needed to verify that the entrusted processing complies with this Agreement, and the Processor responds within a reasonable period.
Where the Controller requests an on-site inspection, the parties agree the scope and timing in advance so that the inspection does not affect other organizations' data.
9.Article 9 (Return and destruction on termination)
When the entrusted work ends, the Processor destroys the entrusted personal information without undue delay, unless the law requires it to be kept, and confirms the destruction to the Controller on request.
Where a retention period in Schedule 1 has not yet expired, the material is destroyed when that period expires. Backups are destroyed on their own cycle.
10.Article 10 (Liability)
Where the Processor causes damage to a data subject by breaching this Agreement, it bears the resulting liability, and where the Controller has compensated the data subject, the Controller may recover from the Processor.
This Article does not limit any liability the Controller bears as the party that determined the purpose and means of the processing.
Contact
For questions about this Agreement, or to request an inspection under Article 8, contact us at:
contact@gangnamx.com