Data Processing Addendum

1. Scope

This addendum forms part of the Terms of Service. It applies when Joy processes personal data on behalf of an office that uses it — about its clients, other parties, staff and candidates — where the Israeli Protection of Privacy Law, 5741-1981, and the Protection of Privacy (Data Security) Regulations, 5777-2017, the GDPR (Regulation (EU) 2016/679) or the UK GDPR apply. The office is the controller; Neos Tech Ltd is the processor.

2. Subject matter, nature and duration

Joy stores, organises, shares and signs the office's documents and records, runs its client, employee and candidate portals and, at the office's request, its AI features. Processing lasts for the subscription and ends with the deletion described in section 8.

3. Types of data and data subjects

Data subjects: the office's clients and their contacts, other parties and witnesses, the office's staff, employees and job candidates, signers and recipients of shared documents. Data: contact and identity details (including ID numbers in know-your-client questionnaires and the employee form 101), the content of documents and messages, signatures and their evidence (time, IP address, device), payroll and tax details, CVs. Special categories (such as health data in a personal injury matter) only as the office chooses to upload them; the office is responsible for having a lawful basis.

4. Instructions and confidentiality

Joy processes personal data only on the office's documented instructions — its use of the service and the settings it chooses are those instructions — unless the law requires otherwise, in which case we tell the office first where the law allows. Everyone at Neos Tech with access to the data is bound by confidentiality. We do not sell the data, do not use it for advertising and do not train models on it.

5. Security

Measures appropriate to the risk, listed in the annex below and reviewed as the service changes.

6. Sub-processors

The office authorises these sub-processors: Netlify, Inc. (website hosting, server functions and document storage; United States, with a global delivery network); Supabase, Inc. (accounts and the cloud database; European Union — Ireland); and, only when the office uses AI features, Anthropic PBC, OpenAI, L.L.C. and Google LLC (the AI models). We impose on each obligations equivalent to this addendum and remain responsible for them. We announce a new sub-processor at least 30 days in advance on this page and in the app; the office may object on reasonable grounds and, if no solution is found, end the subscription. Services the office connects itself (Google Drive, Microsoft, Dropbox, or Claude and ChatGPT as a chat) work under the office's own agreements with them.

7. International transfers

The European Commission recognises Israel as providing adequate protection. Transfers to sub-processors in the United States rely on the EU–U.S. Data Privacy Framework where the sub-processor is certified, and otherwise on the European Commission's standard contractual clauses.

8. Rights, incidents and deletion

The app's tools let the office answer requests for access (export) and erasure (delete all data). We help with other requests and with impact assessments as reasonably needed. We notify the office of a security incident affecting its personal data without undue delay and within 48 hours of becoming aware of it, with the information we have. When the subscription ends, the office can export its data and then delete it; data still held on Joy's servers is deleted within 30 days of a written request, unless the law requires keeping it.

9. Audits

We make available the information needed to show compliance with this addendum and allow an audit on reasonable notice, at the office's cost, once a year and subject to confidentiality.

10. Order of precedence

If this addendum and the Terms of Service conflict about personal data, this addendum prevails. Questions: adir@joyworkos.com.

Annex — security measures

HTTPS only (HSTS) and a strict Content Security Policy; each office's documents separated by its workspace key, with only a hash of the key kept on the server; OAuth 2.1 with PKCE and hashed, short-lived tokens; password-protected share links and data rooms with an access log of every opening; e-signatures with a hash-chained audit trail; permissions by role inside the office; rate limits on public endpoints; row-level security in the cloud database.