Essential Support Data Processing Addendum
Updated August 8, 2026
This Data Processing Addendum (“DPA“) forms part of, and is incorporated by reference into, the Coywolf Terms of Use (the “Terms“) between Coywolf, LLC (“Coywolf,” “we,” “us”) and the Essential Support Workspace Owner (“Customer,” “you”). It applies only to Essential Support and only to the extent Coywolf processes Customer Personal Data on your behalf. Capitalized terms not defined here have the meanings given in the Terms.
1. Self‑serve, click‑accept; no signature or negotiation
This DPA is offered solely on a self‑serve, click‑through basis. You accept and agree to be bound by this DPA when you create or operate an Essential Support Workspace or otherwise use Essential Support. No signature is required, and this DPA is not negotiable. Coywolf does not countersign, execute, or enter into customer‑specific or amended data processing agreements. Your only choices are to accept this DPA by using Essential Support or to not use Essential Support. This DPA constitutes the parties’ agreement on the subject matter of processing Customer Personal Data and satisfies any requirement for a written data processing agreement, including under Article 28(3) of the GDPR and Section 1798.100 et seq. of the CCPA. Coywolf may update this DPA from time to time as described in the Terms and by updating this page.
2. Definitions
- “Customer Personal Data” means personal data contained in Your Content that Coywolf processes on your behalf through Essential Support — for example, the personal data of your End Users contained in tickets, messages, attachments, customer profiles, and related metadata.
- “Data Protection Laws” means all privacy and data‑protection laws applicable to a party’s processing of Customer Personal Data, including, where applicable, the EU General Data Protection Regulation (GDPR), the UK GDPR, and U.S. state privacy laws such as the California Consumer Privacy Act as amended (CCPA).
- “Controller,” “Processor,” “Data Subject,” “Personal Data,” and “Processing” have the meanings given under applicable Data Protection Laws; “Business,” “Service Provider,” and “Sell”/”Share” have the meanings given under the CCPA.
- “Sub‑processor” means a third party engaged by Coywolf to process Customer Personal Data.
- “End User” has the meaning given in the Terms.
3. Roles of the parties
As between the parties, you are the Controller (or Business) of Customer Personal Data, and Coywolf is the Processor (or Service Provider) processing it on your behalf. You are responsible for the accuracy, quality, and legality of Customer Personal Data and for the lawful basis, notices, and consents required to collect it and to have Coywolf process it. Coywolf acts as a Controller only for data described as such in the Privacy Policy (for example, your account and Agent information and Coywolf’s own operational data), which is governed by the Privacy Policy rather than this DPA.
4. Scope and instructions
Coywolf will process Customer Personal Data only (a) to provide, secure, maintain, and improve Essential Support in accordance with the Terms; (b) as further documented in your configuration and use of the Service (for example, your workspace settings, routing, knowledge base, AI configuration, and integrations); and (c) as otherwise instructed by you in writing, where Coywolf agrees such instructions are consistent with the Service. The Terms, this DPA, and your use of the Service constitute your complete and final documented instructions. Coywolf will inform you if it believes an instruction violates Data Protection Laws (without obligation to provide legal advice), and may suspend processing or decline an instruction that falls outside the Service or that would place Coywolf in violation of law.
5. CCPA / U.S. state privacy terms
With respect to Customer Personal Data governed by the CCPA or similar U.S. state laws, Coywolf is a Service Provider. Coywolf will not: (a) Sell or Share Customer Personal Data; (b) retain, use, or disclose it for any purpose other than the business purpose of providing the Service, or as otherwise permitted by law; (c) retain, use, or disclose it outside the direct business relationship between the parties; or (d) combine it with personal data from other sources, except as permitted by the CCPA for a Service Provider. Coywolf certifies that it understands and will comply with these restrictions.
6. Confidentiality and personnel
Coywolf will ensure that personnel authorized to process Customer Personal Data are bound by appropriate confidentiality obligations and process the data only as necessary to provide the Service.
7. Security
Coywolf will implement and maintain the technical and organizational measures described in Annex C to protect Customer Personal Data, appropriate to the risk. You are responsible for your own security decisions within the Service, including managing Agent access and seats, enabling available multi‑factor authentication, safeguarding SSO signing secrets and API keys, and configuring your workspace and integrations securely.
8. Sub‑processors
You provide general authorization for Coywolf to engage the Sub‑processors listed in Annex B and to engage additional or replacement Sub‑processors to provide the Service. Coywolf will impose data‑protection obligations on its Sub‑processors that are substantially consistent with this DPA and remains responsible for their performance of the obligations subject to this DPA. Coywolf will update Annex B (via this page or the Privacy Policy) before or promptly after adding or replacing a Sub‑processor. Because Essential Support is provided on a self‑serve basis, Coywolf does not offer an individual objection‑and‑veto right over Sub‑processors; if you do not accept a Sub‑processor, your remedy is to stop using the Service and close your Workspace. Where you configure your own third‑party keys or integrations (for example, your own AI‑provider keys or storage), those providers are your sub‑processors or processors, not Coywolf’s, and are governed by their terms and your configuration.
9. Data subject requests
Taking into account the nature of the processing, Coywolf will provide self‑serve functionality and reasonable assistance to enable you to respond to requests from Data Subjects to exercise their rights. If Coywolf receives a request from your End User relating to Customer Personal Data, it will, where lawful, direct the individual to you rather than respond directly.
10. Personal data breach
Coywolf will notify you without undue delay after becoming aware of a Personal Data breach affecting Customer Personal Data, and will provide information reasonably available to it to help you meet your notification obligations. Coywolf’s notification is not an acknowledgment of fault or liability. You are responsible for notifying supervisory authorities and affected individuals where required.
11. Assistance and audits
Taking into account the nature of processing and information available to Coywolf, Coywolf will provide reasonable assistance with your data‑protection impact assessments and consultations with authorities. To demonstrate compliance, Coywolf will make available information reasonably necessary to show its obligations under this DPA and, in response to a reasonable written request no more than once per year, will provide relevant documentation (such as summaries of security measures or third‑party reports, where available). Given the self‑serve nature of the Service, on‑site audits are not offered.
12. International transfers
Coywolf stores Customer Personal Data in the United States (see the Privacy Policy). Coywolf does not currently offer EU/UK/Swiss cross‑border transfer safeguards such as the Standard Contractual Clauses. If your use of the Service requires such safeguards, you are responsible for determining whether the Service is appropriate for your use.
13. Deletion and return
Upon termination or expiration of your Workspace, Coywolf will delete Customer Personal Data in accordance with the Terms and the Privacy Policy, including permanent deletion of Workspace data on cancellation, subject to routine backup purge cycles and any retention required by law. Export tools are available for you to retrieve data before termination.
14. Liability
Each party’s and its affiliates’ liability arising out of or related to this DPA is subject to the disclaimers, exclusions, and limitations of liability in the Terms, including the aggregate liability cap. This DPA does not increase any party’s liability beyond what the Terms provide.
15. General
This DPA is governed by the same law and dispute‑resolution and venue provisions as the Terms. In the event of a conflict between this DPA and the Terms regarding the processing of Customer Personal Data, this DPA controls. Except as amended by this DPA, the Terms remain in full force. If any provision of this DPA is unenforceable, it is severed and the remainder stays in effect.
Annex A — Details of processing
- Subject matter: Coywolf’s provision of the Essential Support help‑desk platform to you.
- Duration: For the term of your Workspace, until deletion of Customer Personal Data under Section 13.
- Nature and purpose: Hosting, storing, transmitting, displaying, organizing, securing, scanning, and otherwise processing Customer Personal Data to provide ticketing, support portals, inbound‑email intake, embeddable widgets, knowledge base, AI‑assisted features (such as summaries, suggested replies, automated answers, classification, and translation), notifications, analytics, and related functionality.
- Types of Personal Data: Identifiers and contact details (such as name and email address); account and authentication data; the contents of support tickets, messages, and attachments (which may contain any personal data your End Users choose to include); customer profile data; usage, device, and log data (such as IP address); and any other personal data contained in Your Content.
- Categories of Data Subjects: Your End Users and other individuals whose personal data appears in Your Content, and your Agents.
- Special category data: Not intended. You are responsible for not submitting special‑category or other high‑risk personal data except as appropriate and lawful.
Annex B — Sub‑processors
Coywolf uses the following categories of Sub‑processors to provide Essential Support. This list corresponds to the sub‑processors identified in the Privacy Policy and may be updated there or here.
- Hosting and infrastructure: Render; MongoDB Atlas; Rocket.net; GitHub.
- Storage, content delivery, and security: Cloudflare (including Cloudflare Images, Cloudflare R2, and Cloudflare Turnstile); Backblaze B2; Amazon S3.
- Email delivery and intake: SendGrid; Campaign Monitor.
- Payment processing: Stripe.
- Error monitoring and diagnostics: Sentry.
- Malware scanning: Sieve Nexus (using the ClamAV engine).
- AI providers (subject to your configuration): Anthropic; OpenAI; Google. Where you configure your own AI‑provider keys, the associated provider acts under your account and terms rather than as Coywolf’s Sub‑processor.
Annex C — Technical and organizational security measures
Coywolf maintains measures that include, as applicable:
- Encryption in transit: TLS/HTTPS for data in transit, with HTTP Strict Transport Security and secure, host‑only session cookies in production.
- Encryption at rest: Infrastructure‑level encryption at rest for stored data (for example, via MongoDB Atlas), and additional application‑level AES‑256‑GCM encryption of sensitive per‑workspace secrets and provider API keys.
- Multi‑tenant isolation: Logical separation of workspaces, hostname‑based tenancy resolution, and per‑workspace signing secrets and API keys so that a compromise of one workspace’s secret does not affect others.
- Authentication and access control: Passwordless sign‑in (magic links, SSO handoff, and passkeys/WebAuthn), optional multi‑factor authentication for agents, single‑display of secrets and hashed storage of API keys, and a separately gated, allowlisted, MFA‑protected platform‑admin console with optional IP fencing.
- Malware scanning: Scanning of uploaded files by Sieve Nexus (ClamAV) with withholding of files pending a clean verdict.
- Abuse prevention: Rate limiting, CSRF protection, security headers, bot mitigation (Cloudflare Turnstile), and SSRF protections on outbound webhooks.
- Logging and monitoring: Audit logging of security‑relevant events and error monitoring.
- Data minimization and deletion: Retention aligned to providing the Service and permanent deletion of Workspace data on cancellation, subject to routine backup cycles.
Change log
- August 8, 2026: Essential Support Data Processing Addendum created and published as a self‑serve, click‑accept instrument (no signature or negotiation).