Effective date: 28.05.2026
Last updated: 28.05.2026

These Terms and Conditions ("Terms") form a binding legal agreement between you ("you", "User") and SIA 99articles, a limited liability company incorporated under the laws of the Republic of Latvia ("99articles", "we", "us", "our").

By creating an account, accessing or using the Service (defined below), you confirm that you have read, understood and agree to be bound by these Terms. If you do not agree, you must not access or use the Service.

 

1. Company information

Legal name: SIA 99articles
Legal form: Limited liability company (sabiedrība ar ierobežotu atbildību)
Registration number: 40203703065 
Date of registration: 05.12.2025
Register: Commercial Register of the Republic of Latvia
VAT identification number: LV40203703065
SEPA identifier: LV39ZZZ40203703065
Website: https://99articles.io
Contact: hi@99articles.io

All notices, complaints, copyright reports, withdrawal requests and other communications may be sent to hi@99articles.io.

 

2. Definitions

• "Service" means the 99articles software-as-a-service platform available at 99articles.io, which automates the conversion of audio, video and online video links into structured text articles using third-party artificial intelligence models.
• "User Content" or "Input" means any audio file, video file, URL (including but not limited to YouTube links) or other material you submit to the Service for processing.
• "Output" means the text, transcripts, articles, summaries or other materials generated by the Service from your Input.
• "Account" means your registered user account on the Service.
• "Credits" / "minutes" means the unit of measurement applied to use of the Service (1 minute of processed audio/video = 1 Credit).
• "Consumer" means a natural person acting outside their trade, business, craft or profession, within the meaning of Directive 2011/83/EU and the Latvian Consumer Rights Protection Law (Patērētāju tiesību aizsardzības likums).
• "Business User" means any User that is not a Consumer.
• "Subscription" means a paid recurring plan (Starter, Pro, Media) entered into through the Service.

 

3. The Service

3.1. 99articles is a tool that allows you to upload an audio file (mp3, m4a, aac, ogg), a video file (mp4, mov), or submit a URL to a YouTube video, and receive, in return, a transcript and/or structured article generated using third-party AI models (including, but not limited to, OpenAI's Whisper and language models).

3.2. The processing flow is automated. Uploaded Input files are processed in transit and are deleted immediately after processing. We do not store your Input files. Output is made available within your Account and is stored on our infrastructure as described in our Privacy Policy.

3.3. The Service relies on third-party providers (in particular OpenAI). The availability, accuracy, latency and behaviour of those providers is outside our control. We may change, replace or remove third-party providers at any time, provided the core functionality of the Service is maintained.

3.4. We reserve the right at any time to modify, suspend, throttle or discontinue, in whole or in part, the Service or any feature thereof. For paid Subscribers, where such modification materially diminishes the Service, you may terminate the Subscription as set out in Section 13.

 

4. Eligibility and Account

4.1. You must be at least 16 years old and have full legal capacity to enter into binding contracts in your jurisdiction to use the Service. By using the Service you represent and warrant that you meet this requirement.

4.2. You are responsible for the accuracy of the registration information you provide and for keeping it up to date.

4.3. You are responsible for safeguarding your Account credentials. You must notify us without undue delay at hi@99articles.io of any suspected unauthorised access to your Account. We are not liable for any loss arising from your failure to comply with this obligation, except to the extent such loss results from our own fault.

4.4. You may not (i) create more than one Account for the same individual in order to obtain additional free minutes or otherwise circumvent these Terms, (ii) share, transfer, sell or sublicense your Account, or (iii) use another person's Account.

 

5. User Content — your responsibility

This Section 5 is fundamental. Please read it carefully.

5.1. Sole responsibility. You are solely and exclusively responsible for any User Content you submit to the Service, including (without limitation) the audio files, video files, YouTube URLs and other materials you upload, link to or otherwise transmit, and the use you make of the resulting Output.

5.2. Your warranties. By submitting User Content, you represent and warrant, on a continuing basis, that:

  (a) you own all rights, title and interest in and to the User Content, or you have obtained all necessary licences, permissions, consents, authorisations and waivers (including any required moral-rights waivers) from all relevant rights holders (including authors, performers, producers, broadcasters, platforms and collecting societies) to upload, process, transcribe and generate Output from such User Content for your intended use;

  (b) the User Content and your use of the Service does not and will not infringe, misappropriate or violate any third-party intellectual property right, right of publicity or privacy, contractual right, moral right, trade secret, or any applicable law or regulation (including, without limitation, copyright laws of any jurisdiction, Directive (EU) 2019/790, the YouTube Terms of Service, and any platform-specific terms applicable to the source of the User Content);

  (c) you have obtained any necessary consents from individuals whose voice, image, likeness or personal data appears in or can be derived from the User Content;

  (d) the User Content does not contain unlawful material, including content that is defamatory, obscene, sexually explicit involving minors, hateful, harassing, threatening, fraudulent, or that promotes terrorism or violence; and

  (e) your use of the Service complies with all applicable laws and with the terms of any third-party platform from which the User Content originates.

5.3. YouTube and third-party sources. You acknowledge that downloading or processing audio or video from YouTube or any other third-party platform may be restricted by that platform's terms of service and by applicable copyright law. You are solely responsible for ensuring that your use of any third-party content complies with the rights holder's terms and applicable law. 99articles does not endorse, encourage or authorise any infringing use of third-party content.

5.4. No verification. We do not, and have no obligation to, screen, verify, monitor, edit or otherwise review User Content for legality, ownership, accuracy or compliance with these Terms. The Service operates as an automated tool. We are not a publisher of User Content or Output.

5.5. Indemnity. You agree to defend, indemnify and hold harmless 99articles, its owners, directors, officers, employees, contractors, agents, successors and assigns (the "Indemnified Parties") from and against any and all claims, demands, proceedings, losses, liabilities, damages, fines, penalties, costs and expenses (including reasonable attorneys' fees and court costs) arising out of or in connection with:

  (a) your User Content;

  (b) your Output, and any use you make of it;

  (c) any breach by you of any representation, warranty or obligation under these Terms;

  (d) your violation of any applicable law or any rights of any third party (including, without limitation, intellectual property, privacy, publicity or contractual rights); and

  (e) your use or misuse of the Service.

This indemnity applies to the fullest extent permitted by applicable law. Where you are a Consumer, this indemnity is limited to losses caused by your culpable breach (intent or negligence) and only to the extent that such losses are a foreseeable consequence of that breach; nothing in this Section extends your liability beyond what is permitted by mandatory Consumer protection law.

5.6. Removal and termination. Without limiting our other rights, we may remove any User Content or Output from our systems, suspend your access to the Service, and/or terminate your Account at any time, if we reasonably believe that you are in breach of this Section 5, or if we receive a credible third-party complaint or legal notice in respect of your User Content.

5.7. Data Processing. Where you upload User Content containing personal data of third parties in your capacity as a Business User, our processing of such data is governed by the Data Processing Addendum set out in Annex B.

 

6. Copyright complaints (notice and takedown)

6.1. We respect intellectual property rights and expect our Users to do the same. If you are a rights holder (or their authorised representative) and you believe that User Content or Output processed via the Service infringes your copyright, please send a notice to hi@99articles.io containing:

  (a) your full name, postal address, telephone number and email;

  (b) identification of the copyrighted work claimed to have been infringed;

  (c) identification of the allegedly infringing material and sufficient information to enable us to locate it (e.g., URL, Account username, date);

  (d) a statement that you have a good-faith belief that the use is not authorised by the rights holder, its agent or the law;

  (e) a statement that the information in the notice is accurate and that you are the rights holder or are authorised to act on behalf of the rights holder; and

  (f) your physical or electronic signature.

6.2. We will act on properly formulated notices without undue delay and may, in our reasonable discretion, remove the allegedly infringing material, suspend the responsible Account, or take any other action we deem appropriate. Repeat infringers will have their Accounts terminated.

6.3. Knowingly submitting a false or misleading notice may expose you to liability for damages under applicable law.

 

7. Intellectual property

7.1. Our rights. All rights, title and interest in and to the Service, the "99articles" name and brand, the underlying software, design, "look and feel", databases, documentation and all related intellectual property (including any trademarks, whether registered or unregistered, and excluding User Content and, as between you and us, Output) are and remain the exclusive property of 99articles and/or its licensors. Nothing in these Terms transfers any such rights to you. You may not use our name, brand or logos without our prior written consent.

7.2. Your Input. As between you and us, you retain all rights, title and interest in and to your User Content. By submitting User Content, you grant us a worldwide, non-exclusive, royalty-free, fully paid-up licence to host, process, transmit and transcribe the User Content solely for the purpose of providing the Service to you, for the duration strictly necessary to process the Input (after which the Input is deleted as described in Section 3.2). We do not use User Content to train AI models, and our AI processor is contractually prohibited from doing so.

7.3. Output. Subject to your compliance with these Terms and to the extent permitted by applicable law, as between you and us, you own the Output generated from your Input. However, you acknowledge that:

  (a) under settled EU and Latvian copyright law, only "an author's own intellectual creation" qualifies for copyright protection; purely AI-generated material without sufficient human creative contribution may not be eligible for copyright protection at all;

  (b) Output may not be unique to you — other Users providing similar Inputs may receive substantially similar Outputs from the underlying AI models;

  (c) Output may incorporate or reflect elements of pre-existing works, including the User Content itself, and you remain solely responsible for ensuring that your use, publication or commercialisation of Output does not infringe any third-party right; and

  (d) we make no representation or warranty that the Output is original, accurate, non-infringing, complete or fit for any particular purpose.

7.4. Feedback. If you submit feedback, suggestions or ideas to us, you grant us a perpetual, worldwide, irrevocable, royalty-free licence to use such feedback for any purpose, without obligation or compensation to you.

 

8. AI disclaimers and acceptable use

8.1. Nature of AI Output. The Service uses generative AI. Output may be inaccurate, incomplete, outdated, biased, offensive, or otherwise unsuitable for your purposes ("hallucinations"). Output is not professional advice (legal, medical, financial, journalistic or otherwise). You must independently verify any Output before relying on it, publishing it, or making decisions based on it.

8.2. No newsroom guarantee. Although the Service generates news-article-style text, 99articles is not a media outlet, news agency or publisher, and the Output is not journalism. We do not fact-check, edit or vouch for any Output.

8.3. Prohibited uses. You agree not to use the Service to:

  (a) process content you do not own or have permission to process;

  (b) infringe any intellectual property, privacy, publicity, moral or contractual right;

  (c) generate, distribute or facilitate disinformation, deepfakes, non-consensual intimate imagery, child sexual abuse material, content sexualising minors, terrorist or violent extremist content, harassment, or unlawful threats;

  (d) circumvent technical protection measures or platform terms (including YouTube's Terms of Service);

  (e) interfere with, probe, scan, or test the vulnerability of the Service, or breach any security or authentication measure;

  (f) reverse engineer, decompile, disassemble or otherwise attempt to derive the source code of the Service, except to the extent expressly permitted by mandatory applicable law;

  (g) use the Service to build a competing product, or to train, fine-tune or improve any AI model;

  (h) resell, sublicense or commercially redistribute access to the Service without our prior written consent;

  (i) use automated means (bots, scrapers) to access the Service in a manner inconsistent with these Terms or that imposes an unreasonable load on our infrastructure;

  (j) violate any applicable law or regulation, including export controls and sanctions.

  (k) you must not upload special categories of personal data (e.g., health, biometric data) unless you have a valid legal basis to do so.

8.4. We may, in our reasonable discretion, suspend, throttle or terminate access for any User reasonably suspected of breaching this Section 8.

 

9. Plans, free minutes, Credits, payment and taxes

9.1. Free minutes. Upon first registration, each new User receives a one-time allocation of 15 free minutes (15 Credits) to trial the Service. This allocation is granted once per User, is not recurring, is not renewed once used, and has no cash value. Attempts to obtain additional free minutes by creating multiple Accounts are prohibited (Section 4.4).

9.2. Paid plans. After the free minutes are used, continued use requires a paid plan, as described on https://99articles.io/pricing:

  - Starter — EUR 9 / month;

  - Pro — EUR 19 / month;

  - Media — EUR 49 / month.

Each paid plan includes a monthly allocation of minutes/Credits as stated on the pricing page. Prices are stated exclusive of VAT, which will be added where applicable. We may change prices at any time; changes take effect at your next billing period and you will be notified in advance. Continued use after a price change constitutes acceptance.

9.3. "Use it or lose it" — Credit expiry. Your monthly allocation of minutes/Credits is renewed at the start of each billing period following payment and expires at the end of that billing period. Unused minutes/Credits do not roll over to the next period and are not refunded. This is a core feature of the Service and is disclosed to you before purchase.

9.4. Billing via Stripe. Payments are processed by Stripe Payments Europe, Ltd. ("Stripe"). By providing payment information, you authorise us (via Stripe) to charge the applicable fees on a recurring basis. You are responsible for ensuring that your payment method is valid and has sufficient funds. We do not store full payment-card data; see our Privacy Policy.

9.5. Auto-renewal and cancellation. Subscriptions renew automatically at the end of each billing period at the then-current price unless cancelled before the renewal date. You may cancel at any time from your Account settings. Cancellation stops future renewals; your access continues until the end of the current paid period, after which it ends.

9.6. Failed payments. If a payment fails, we may suspend or downgrade your Account until payment is received. We may pass on any reasonable costs incurred (e.g., chargeback fees) to the extent permitted by law.

9.7. Taxes. Prices do not include taxes unless stated. You are responsible for any taxes payable on your purchase, except for taxes based on our net income.

 

10. Refunds

10.1. No voluntary refunds. Except where a refund is mandatory under applicable law (in particular Sections 10.2 and 11.1), all fees are non-refundable. In particular, and without limiting your statutory rights:

  (a) if you cancel a Subscription mid-cycle, you will not receive a pro-rata or partial refund for the remainder of that billing period; your access simply continues until the end of the period already paid for; and

  (b) unused minutes/Credits are not refunded and expire as described in Section 9.3.

10.2. Mandatory exceptions. Nothing in this Section 10 affects:

  (a) the statutory right of withdrawal for Consumers under Section 11; or

  (b) the statutory legal guarantee of conformity under Directive (EU) 2019/770 and the Latvian Consumer Rights Protection Law, under which Consumers are entitled to a remedy (which may include a refund) where the Service is not in conformity with the contract.

 

11. Right of withdrawal (Consumers in the EU/EEA)

This Section applies only to Consumers. Business Users have no right of withdrawal.

11.1. Statutory right. If you are a Consumer domiciled in the EU/EEA, you have the right under Directive 2011/83/EU and the Latvian Consumer Rights Protection Law to withdraw from your Subscription contract within fourteen (14) days of its conclusion, without giving any reason.

11.2. How to exercise. To exercise the right of withdrawal, you must inform us by an unambiguous statement (e.g., email to hi@99articles.io, or by using the model withdrawal form in Annex A) of your decision to withdraw. To meet the deadline, it is sufficient to send your communication before the 14-day period has expired.

11.3. Effects of withdrawal. If you withdraw, we will reimburse all payments received from you in respect of the withdrawn contract without undue delay, and no later than 14 days from the day we receive your withdrawal notice. We will use the same means of payment used for the initial transaction unless you expressly agree otherwise; you will incur no fees as a result of the reimbursement.

11.4. Express request for immediate performance and loss of the right. Because the Service is a digital service performed online and consumed instantaneously, you may expressly request that performance begin immediately upon purchase. You acknowledge that, in accordance with Article 16(m) of Directive 2011/83/EU and the Latvian implementing rules (Cabinet Regulation No. 255 "Regulations Regarding Distance Contracts"), once performance has begun with your prior express consent and your acknowledgement that you thereby lose your right of withdrawal — including where you begin processing any Input during the 14-day period — your right of withdrawal is extinguished. This express consent and acknowledgement is obtained from you at checkout. If you do not give such consent and do not begin using the Service, your 14-day right of withdrawal remains unaffected.

11.5. Free minutes. No fee is charged for the one-time 15 free minutes, and the right of withdrawal does not give rise to any reimbursement claim in respect of unpaid use.

 

12. Warranties and disclaimer

12.1. Statutory rights of Consumers. Nothing in these Terms affects any non-excludable statutory rights you may have as a Consumer, including the right to a service in conformity with the contract under Directive (EU) 2019/770 and Latvian implementing legislation.

12.2. "As is". To the maximum extent permitted by applicable law, and subject to Section 12.1:

> THE SERVICE AND ALL OUTPUT ARE PROVIDED "AS IS" AND "AS AVAILABLE", WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND, EXPRESS, IMPLIED OR STATUTORY. 99ARTICLES, ITS AFFILIATES, OWNERS, EMPLOYEES, CONTRACTORS AND LICENSORS DISCLAIM ALL WARRANTIES, INCLUDING, WITHOUT LIMITATION, IMPLIED WARRANTIES OF MERCHANTABILITY, SATISFACTORY QUALITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, NON-INFRINGEMENT, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE. WE DO NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, SECURE, ACCURATE OR COMPLETE, OR THAT DEFECTS WILL BE CORRECTED, OR THAT OUTPUT WILL MEET YOUR REQUIREMENTS OR EXPECTATIONS.

12.3. AI-specific disclaimer. Without limiting Section 12.2, we make no warranty whatsoever as to (a) the accuracy, completeness, originality or non-infringement of any Output; (b) the suitability of any Output for your intended purpose; or (c) the legal status of any Output under copyright law in any jurisdiction. Any use of Output is at your sole risk.

 

13. Limitation of liability

13.1. Excluded losses. To the maximum extent permitted by applicable law, in no event will 99articles, its owners, directors, employees, contractors, agents or licensors be liable for any:

  (a) indirect, incidental, special, consequential, exemplary or punitive damages;

  (b) loss of profits, revenue, goodwill, anticipated savings, business, contracts or opportunity;

  (c) loss, corruption or unavailability of data;

  (d) loss arising from any User Content or Output, including any allegation of intellectual property infringement, defamation, privacy violation or unlawful content; or

  (e) loss arising from any act or omission of any third-party provider (including OpenAI, Stripe, Hetzner or YouTube),

even if we have been advised of the possibility of such damages and even if a limited remedy fails of its essential purpose.

13.2. Aggregate cap. To the maximum extent permitted by applicable law, our total aggregate liability to you under or in connection with these Terms, the Service or any Output, whether in contract, tort (including negligence), breach of statutory duty, restitution or otherwise, will not exceed the greater of (i) the total amount you have actually paid to us in the twelve (12) months preceding the event giving rise to the claim, or (ii) one hundred euros (EUR 100).

13.3. Non-excludable liability. Nothing in these Terms excludes or limits our liability for: (a) death or personal injury caused by our negligence; (b) fraud or fraudulent misrepresentation; (c) wilful misconduct or gross negligence; (d) any liability that cannot be excluded or limited under applicable law (including non-excludable Consumer rights under Latvian and EU law); or (e) our obligations under the GDPR.

13.4. Consumer position. If you are a Consumer, the limitations and exclusions in this Section 13 apply only to the extent permitted by mandatory Consumer protection law; where Latvian Consumer law affords you greater rights, those rights prevail. The limitations apply in full to Business Users.

13.5. Allocation of risk. You acknowledge that the limitations in this Section 13 are a fundamental basis of the bargain between you and us and reflect a reasonable allocation of risk given the price of the Service.

 

14. Term, suspension and termination

14.1. These Terms remain in force for as long as you maintain an Account.

14.2. Termination by you. You may terminate by cancelling your Subscription and deleting your Account from the settings panel at any time, subject to Sections 9.5 and 10.

14.3. Termination/suspension by us. We may suspend or terminate your access to the Service and/or your Account, immediately and (subject to mandatory law) without refund, if:

  (a) you are in material breach of these Terms (including Sections 5, 6 or 8);

  (b) we receive a credible third-party complaint or legal demand concerning your User Content or Output;

  (c) your use poses a security, legal or reputational risk to us or to other Users;

  (d) required by applicable law, court order or competent authority; or

  (e) we cease providing the Service generally (in which case we will refund any pre-paid, unused Subscription fee on a pro-rata basis).

14.4. Effect of termination. Upon termination, your right to access and use the Service ceases. Provisions which by their nature should survive (including Sections 5, 6, 7, 12, 13, 15, 16 and 17) will survive.

 

15. Third-party services

15.1. The Service integrates with third-party services, including OpenAI (AI processing), Stripe (payment processing), Hetzner Online GmbH (hosting) and YouTube (as a source of User Content). Your use of those services may be governed by their own terms and privacy policies, and you are responsible for complying with them.

15.2. We are not responsible for, and disclaim all liability arising from, any act, omission, failure, outage, change or discontinuation of any third-party service.

 

16. Changes to these Terms

16.1. We may amend these Terms from time to time. The "Last updated" date at the top will reflect the latest version.

16.2. Material changes will be notified to you by email and/or in-app notice at least 30 days before they take effect. If you do not agree, you may terminate the affected Subscription before the changes take effect; continued use after the effective date constitutes acceptance.

16.3. Non-material changes (e.g., clarifications, typographical corrections, changes mandated by law) take effect upon publication.

 

17. Governing law, jurisdiction and dispute resolution

17.1. Governing law. These Terms and any non-contractual obligations arising out of or in connection with them are governed by the laws of the Republic of Latvia, without regard to its conflict-of-laws principles, and (where applicable) by mandatory provisions of EU law. If you are a Consumer, you also benefit from the mandatory protections of the law of your country of habitual residence under Article 6 of Regulation (EC) No 593/2008 (Rome I).

17.2. Jurisdiction. Subject to Section 17.3, the courts of the Republic of Latvia have jurisdiction. If you are a Consumer, you may also bring proceedings in the courts of your country of residence, and you may only be sued in the courts of your country of residence.

17.3. Out-of-court dispute resolution (Consumers).

  (a) Complaints to us. You may at any time submit a complaint to hi@99articles.io. We will acknowledge it within 5 working days and aim to resolve it within 30 days.

  (b) Latvian Consumer Rights Protection Centre (PTAC). Consumers may file a complaint with the Patērētāju tiesību aizsardzības centrs, Brīvības iela 55, Riga, LV-1010, Latvia; email ptac@ptac.gov.lv; https://www.ptac.gov.lv/.

  (c) EU consumer dispute-resolution bodies. The European Commission's Online Dispute Resolution platform was discontinued on 20 July 2025. A list of certified alternative dispute resolution (ADR) entities across the EU Member States, Norway and Iceland is available at https://consumer-redress.ec.europa.eu/dispute-resolution-bodies. Consumers may also contact their national European Consumer Centre (ECC).

17.4. We are not obliged to use, and do not commit to using, any specific ADR entity, but we will engage in good faith with PTAC proceedings where they apply.

 

18. Miscellaneous

18.1. Entire agreement. These Terms (together with the Privacy Policy and any documents referenced in them) constitute the entire agreement between you and 99articles regarding the Service and supersede any prior agreements.

18.2. No waiver. Our failure to enforce any provision is not a waiver of our right to do so later.

18.3. Severability. If any provision is held invalid, illegal or unenforceable, the remaining provisions remain in full force; the invalid provision will be replaced by a valid provision that most closely reflects the original intent. For Consumers, this clause is applied so as not to deprive you of mandatory statutory protections.

18.4. Assignment. You may not assign these Terms without our prior written consent. We may assign these Terms to an affiliate or to a successor in connection with a merger, acquisition or sale of assets, provided your rights are not materially diminished.

18.5. Force majeure. We are not liable for any failure or delay in performance caused by events beyond our reasonable control (including acts of God, war, terrorism, pandemic, government action, internet or third-party provider outages, denial-of-service attacks, or industrial disputes).

18.6. Notices. Notices to you will be sent by email to your registered Account address or posted in-app. Notices to us must be sent to hi@99articles.io (with a copy by registered mail to our legal address where required by law).

18.7. Language. These Terms are concluded in English. A Latvian translation may be made available for convenience; in case of discrepancy, the English version prevails, except where mandatory Consumer protection law of your country of residence requires otherwise.

18.8. Relationship. Nothing in these Terms creates any agency, partnership, joint venture or employment relationship.

 

Annex A — Model withdrawal form (Consumers)

(Complete and return this form only if you wish to withdraw from the contract.)

> To: hi@99articles.io

>

> I/We (*) hereby give notice that I/We (*) withdraw from my/our (*) contract for the supply of the following service:

>

> Ordered on (*): ____________

> Name of consumer(s): ____________

> Address of consumer(s): ____________

> Account email: ____________

> Signature of consumer(s) (only if this form is notified on paper): ____________

> Date: ____________

>

> (*) Delete as appropriate.

 

Annex B – Data Processing Addendum

DATA PROCESSING ADDENDUM (DPA)

This Data Processing Addendum ("DPA") forms part of the Terms and Conditions ("Agreement") between SIA 99articles, Reg. No. 40203703065, Latvia ("Processor" or "99articles") and the Business User ("Controller" or "Customer").

 1. Subject Matter and Scope

1.1. This DPA applies to the extent that 99articles processes Personal Data on behalf of the Controller as a Processor under Article 28 of the General Data Protection Regulation (EU) 2016/679 ("GDPR") while providing the Service (automated conversion of audio/video to structured text via AI).

1.2. Nature and Purpose of Processing: Processing of uploaded audio/video files (Input) to generate transcripts and structured articles (Output).

1.3. Types of Personal Data: Voice recordings, names, and any other personal data contained within the User Content uploaded by the Controller.

1.4. Categories of Data Subjects: Individuals whose voices or personal information are recorded or mentioned in the uploaded User Content.

 

 2. Obligations of the Processor (99articles)

2.1. Instructions: The Processor shall process Personal Data only on documented instructions from the Controller, including with regard to transfers of personal data to a third country, unless required to do so by EU or Latvian law. The Agreement and the User's use of the Service constitute the complete instructions.

2.2. Confidentiality: The Processor shall ensure that persons authorised to process the Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

2.3. Security: The Processor implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including TLS encryption in transit and encryption at rest. The Controller acknowledges that the Service does not use end-to-end or "zero-knowledge" encryption.

2.4. Assistance: The Processor shall assist the Controller by appropriate technical and organisational measures, insofar as possible, for the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights laid down in Chapter III of the GDPR.

2.5. Compliance & DPIA: The Processor shall assist the Controller in ensuring compliance with the obligations pursuant to Articles 32 to 36 of the GDPR, taking into account the nature of processing and the information available to the Processor.

 

3. Subprocessors

3.1. The Controller grants the Processor a general written authorisation to engage subprocessors. 

3.2. As of the Effective Date, the authorised subprocessors are:

(a) OpenAI Ireland Limited (and its U.S. affiliate): For AI processing. Processing is strictly configured with Zero Data Retention; Input data is not retained and is not used to train AI models.

(b) Hetzner Online GmbH (Germany): For application hosting and data storage.

3.3. The Processor shall inform the Controller of any intended changes concerning the addition or replacement of subprocessors, giving the Controller the opportunity to object to such changes.

 

4. International Data Transfers

4.1. If the Processor transfers Personal Data outside the European Economic Area (EEA) to a country lacking an adequacy decision (e.g., to OpenAI in the U.S.), the Processor shall ensure appropriate safeguards are in place, such as the EU Standard Contractual Clauses (SCCs) and/or reliance on the EU-U.S. Data Privacy Framework.

 

5. Data Breach Notification

5.1. The Processor shall notify the Controller without undue delay after becoming aware of a personal data breach affecting the Controller's Personal Data, providing sufficient information to allow the Controller to meet its own reporting obligations.

 

6. Deletion or Return of Data

6.1. Input Data: The Processor automatically deletes all audio/video Input files immediately after the AI processing is complete.

6.2. Output Data: The Processor shall delete Output data (generated articles/transcripts) within 30 days of the Controller deleting their Account, except where longer retention is required by applicable law. 

 

7. Audits and Inspections

7.1. The Processor shall make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in Article 28 of the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller.