This baseline DPA is available before signature. A signed customer-specific DPA controls if it conflicts with this page.
Optional managed AI review
When an organisation owner enables managed AI review, selected repository code, diffs and review context are sent to Nebius using Pillion’s provider account. Nebius is a subprocessor for this optional service. Public serverless inference has no EU-only residency promise from Pillion; the selected endpoint and provider agreement determine processing location. Bring-your-own-key reviews use the customer’s chosen provider and agreement.
1. Scope and instructions
The customer is the controller and Pillion is the processor for personal data in Customer Data. Customer Data includes native source history, changes, agent tasks, checkpoints, saved conversations, selected prompts, tool results, and review evidence. It also includes issues, pull requests, comments, attachments, workflow records, and organisation administration data. Pillion processes that data only to provide, secure, support, and improve the service as documented by the customer, including storing, indexing, backing up, transmitting, displaying, and deleting it. The documented instructions are the Terms of Service, the order, use of the service, and later written instructions that do not require a material change to the service.
2. Customer responsibilities
The customer is responsible for having a lawful basis and notices for the personal data it submits, responding to data-subject requests where it is the controller, and configuring users, repositories, runners, retention, and webhooks appropriately.
3. Confidentiality and personnel
Pillion keeps Customer Data confidential and gives access only to personnel who need it to operate or support the service. Those personnel are bound by confidentiality obligations. Pillion does not use Customer Data to train models.
Uploaded conversations remain private to their creator. Sharing publishes selected events at a fixed revision to current repository collaborators. Public repository visibility does not make private conversations public.
4. Security measures
Pillion maintains security measures appropriate to the risk. Native source objects, saved agent context, blobs, Postgres, caches, artefacts, and backups use encryption at rest. Connections use TLS. Controls include authentication, access checks, audit logging, vulnerability management, change management, backups, restore drills, rate limits, and emergency operator access. Pillion encrypts stored workflow secrets and excludes secret values from logs. Hosted jobs run in isolated microVMs. Attached runners remain customer-operated.
5. Subprocessors
The current list is published at /subprocessors. Pillion gives at least 30 days’ notice before adding or replacing a subprocessor. Customers may object on reasonable data-protection grounds during that period. Pillion will either avoid the change for that customer, provide a commercially reasonable alternative, or allow the customer to terminate the affected service. Objections may be sent to info@pillion.dev.
Paddle receives billing contact, purchase and payment information as our authorised reseller and Merchant of Record. It acts as an independent controller for that data under its privacy notice. Paddle may process billing data internationally; this processing is outside Pillion’s core source and collaboration data residency commitment. Repository contents are not sent to Paddle for billing. Paddle privacy notice.
6. Data-subject and regulator assistance
Taking account of the processing, Pillion will reasonably assist the customer with access, correction, deletion, restriction, portability, objection, and security-obligation requests. Pillion will provide information reasonably needed to demonstrate compliance and will notify the customer without undue delay after confirming a personal-data breach affecting Customer Data.
7. International transfers
Pillion’s core source and product stores are operated in the allowed geography described on our trust page. A customer must not use the service to send personal data to an external integration unless it has a lawful basis and appropriate transfer mechanism. Payment processing is a separate path: Paddle’s own privacy terms govern its processing and may permit processing outside the EEA with an appropriate transfer mechanism.
The core boundary covers stored source, agent tasks, checkpoints, saved conversations, and review evidence. Customer-operated harnesses, attached runners, and chosen model providers control their own processing. External processing requires the customer’s instructions and applicable provider terms. Core storage residency does not promise EU-only model inference.
8. Return and deletion
On request or termination, Pillion will make Customer Data export available through the service and delete it according to the retention and deletion controls in the Terms of Service, unless law requires retention. Backups are reaped according to the configured retention window and are not used to restore deleted customer data except for disaster recovery before expiry.
Source exports use Git-compatible formats. Private conversations and other agent metadata require separate exports with current authorisation. A source export does not include private agent context.
Checkpoints expire at their recorded deadlines. Deleting a conversation clears its content from the thread, published ranges, and descendant forks. Minimal records prevent retries from restoring deleted content. Server deletion does not remove local recorder queues or downloaded exports. Backups follow their configured retention.
9. Audits
Pillion will make available information reasonably necessary to show compliance with this DPA. Once per year, and after a material incident, the customer may request a remote audit or independent report on reasonable notice, subject to confidentiality and security controls. Audits may not expose another customer’s data or materially disrupt the service.
10. Term and order of precedence
This DPA starts when the customer uses the service or signs an order and ends when Pillion has deleted or returned Customer Data, subject to lawful retention. The confidentiality, security, deletion, and audit obligations continue for as long as Pillion retains Customer Data. The Terms of Service control on service and commercial matters; this DPA controls on processing of personal data.
DPA requests: info@pillion.dev.