DATA PROCESSING AGREEMENT
BETWEEN: USER (CONTROLLER) AND NEWLIFE (PROCESSOR)
01. DEFINITIONS
"Personal Data" means any information relating to an identified or identifiable natural person. "Processing" means any operation performed on Personal Data. "Controller" determines the purposes and means of processing. "Processor" processes data on behalf of the Controller.
02. PURPOSE & NATURE
NEWLIFE processes Personal Data solely to provide the AIOS Smart Home services, including local intent recognition, environmental automation, and energy optimization.
LOCAL FIRST POLICY
The Processor warrants that 99% of data processing occurs locally on the User's DeepWall Core hardware.
03. SECURITY MEASURES
The Processor implements technical and organizational measures to ensure a level of security appropriate to the risk, including pseudonymization and encryption of Personal Data.
04. SUB-PROCESSORS
The Controller grants general authorization to engage the following sub-processors for cloud-based large model inference. All data sent is stripped of PII before transmission.
05. DATA SUBJECT RIGHTS
The Processor shall assist the Controller in fulfilling obligations to respond to requests for exercising data subject rights. Users may execute a "Digital Incineration" command to permanently wipe local storage.
06. TERMINATION
Upon termination of the Service Agreement, the Processor shall delete all Personal Data within 24 hours, unless Union or Member State law requires storage of the Personal Data.
DATE: 2025.11.30