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Draft for counsel review. Not in force.

TrueSit data processing addendum

Version 0.1, 2026-10-11. This addendum (“DPA”) is part of the TrueSit terms of use (or the order form) between DMS Consultation Inc. (“TrueSit”) and the organization using TrueSit (the “Customer”). Counsel writes and signs the final text. Nothing here is legal advice.

1. Roles

  • The Customer decides why and how personal information in Customer Data is processed. TrueSit processes it on the Customer’s behalf as its service provider (a “processor” or “contractor” under state laws that use those words).
  • This DPA covers personal information in Customer Data: about the Customer’s users, the homeowners and others its reps record, and the households in its records.
  • It does not cover data TrueSit handles for its own purposes under its privacy policy (website visitors, walkthrough requests, billing contacts, platform security logs).

2. Instructions

  • TrueSit processes Customer Data only to provide, secure and support the Service, on the Customer’s documented instructions. These terms, the Customer’s settings and its users’ actions in the Service are those instructions.
  • The product improvement switch is an instruction: TrueSit uses the contents of recordings and transcripts to improve the Service only while an org admin has it turned on. It is off by default.
  • TrueSit tells the Customer if it believes an instruction breaks the law, and may pause that processing until it is resolved.

3. California service provider terms

TrueSit:

  • does not sell or share Customer Data, and does not use it for cross-context behavioral advertising;
  • does not retain, use or disclose it for any purpose other than the business purposes in this DPA, or outside the direct business relationship with the Customer;
  • does not combine it with personal information from other sources, except as the law allows a service provider to;
  • complies with the California Consumer Privacy Act as it applies to service providers, gives the same level of protection the law requires, and tells the Customer if it can no longer meet these duties; and
  • allows the Customer to take reasonable steps to stop and fix unauthorized use, as section 9 describes.

4. People who process Customer Data

TrueSit staff with access to Customer Data are bound by confidentiality, trained on these duties, and get access only as their role needs. Access through the platform console is read-only by default, limited to 30 minutes, requires a typed reason, and is logged in a log the Customer’s org admins can read. Recordings play for TrueSit staff only when an org admin has granted support access to that sit.

5. AI processing

  • The Service uses the AI providers listed on the subprocessor page. TrueSit’s contracts with them bar training their own models on Customer Data.
  • AI support tools may read support tickets, the Customer’s members and plan, and a sit’s technical state, to draft replies and propose fixes. They do not act on the Customer’s account or write to the Customer without approval by TrueSit staff, except an acknowledgement and marking a ticket resolved after the Customer confirms, where the platform owner allows them.
  • The help assistant answers only from public help articles and has no access to Customer Data.

6. Biometric processing

  • Rep voiceprints. Before enrollment, the Service shows each rep the voiceprint release and records the rep’s agreement, its time and its version, on the Customer’s behalf. Enrollment is optional. TrueSit uses the voiceprint only to tell the rep’s voice apart in the rep’s own sits, never sells it, never profits from it beyond providing the Service, and never discloses it except to the subprocessors that host it.
  • Retention. TrueSit destroys each voiceprint at the earliest of: the end of the Customer’s voiceprint period (24 months after enrollment by default, 6 to 36 months as the Customer sets); when the rep leaves the Customer’s organization; when the rep deletes it; at account deletion; or at the Customer’s closure. A scheduled job enforces it and logs each destruction.
  • Other speakers. Voice features of homeowners and other speakers are computed only while one sit is processed, deleted when processing ends, never compared across sits, and never used to identify anyone.
  • Customer duties. The Customer does not require enrollment as a condition of work, gives any notice its states require, and tells TrueSit when a rep leaves (removing the member in Settings does this).

7. Subprocessors

  • The Customer authorizes the subprocessors listed at truesit.ai/legal/subprocessors.
  • TrueSit binds each subprocessor by written contract to protections at least as strong as this DPA, and remains responsible for them.
  • TrueSit notifies org admins by email at least 30 days before adding or replacing a subprocessor. The Customer may object on reasonable data protection grounds within that period. If we cannot address the objection, the Customer may end the affected part of the Service and receive a refund of prepaid fees for it.
  • In an emergency (a provider failing or a security threat), TrueSit may replace a subprocessor at once and notifies the Customer as soon as it can.

8. Security

TrueSit keeps the technical and organizational measures in Annex 2 and may improve them, but will not lower the overall protection during the subscription.

9. Assistance and audits

  • Requests. TrueSit gives the Customer tools to export, correct and delete Customer Data, and routes to the Customer any request it receives about Customer Data (including homeowners’ requests) within 5 business days. TrueSit does not answer such requests itself except to confirm receipt and say where it was routed, unless the Customer asks it to.
  • Assessments. TrueSit provides reasonable information the Customer needs for its own risk assessments, including for automated decision rules and AI-in-employment notices.
  • Audits. TrueSit answers a reasonable security questionnaire once a year and shares the security overview and, once they exist, independent audit reports. If those do not answer a regulator’s or the Customer’s reasonable concern, the Customer may audit once a year on 30 days’ notice, at its cost, during business hours, under confidentiality.

10. Security incidents

  • TrueSit notifies the Customer without undue delay, and within 72 hours, after confirming a breach of security that leads to unauthorized access to, or loss or disclosure of, Customer Data.
  • The notice says what happened, the data and people affected as far as known, what TrueSit has done and recommends, and a contact. TrueSit updates it as it learns more.
  • TrueSit helps the Customer meet its own notice duties to people and regulators. Notifying the Customer is not an admission of fault.

11. Government and legal requests

TrueSit discloses Customer Data to a government or in litigation only when legally required, after checking the request is valid, disclosing the minimum, and telling the Customer first unless the law forbids it.

12. Data location

Customer Data is stored in the United States. A subprocessor outside the United States is named as such on the subprocessor page before it is used.

13. Return and deletion

  • During the subscription, org admins export Customer Data from Settings at any time.
  • After termination, the Customer has 30 days to export. TrueSit then deletes Customer Data within 30 days, and it leaves backups within a further 30 days, except where the law requires TrueSit to keep it; anything kept stays protected by this DPA.
  • At the Customer’s request, TrueSit confirms deletion in writing.

14. Liability and order of precedence

Each party’s liability under this DPA is subject to the limits in the terms of use, except as the terms state otherwise. If this DPA and the terms conflict on data protection, this DPA wins.

Annex 1: Details of processing

  • Subject matter and duration. Providing the Service for the subscription and the deletion period after it.
  • Purpose. Recording, transcribing, analyzing and scoring sales visits; mentoring reps; reporting to the Customer; support; security.
  • People. The Customer’s users; homeowners and others present at recorded sits or canvass doors; household contacts in the Customer’s records.
  • Personal information. Account and device details; audio, photos and transcripts; AI output; household records (names, address, phone, email, who decides, project, budget, other bids, decision style); optional location at the start and end of sits and canvass doors; rep voiceprints; Mentor memory; support tickets about the Customer’s account.
  • Sensitive information. Rep voiceprints (biometric) and precise location, used only as described above.
  • Retention. As the retention schedule states (truesit.ai/legal/retention).

Annex 2: Security measures

  • Recordings encrypted on the phone (AES-GCM, keys in the phone’s secure keystore) before upload; TLS in transit; encryption at rest in storage and backups.
  • Row-level access rules on every database table; each organization’s data kept apart; each role limited to what it may see; tested per role, with a mutation check that breaks each rule in turn to prove a test catches it.
  • Short-lived, logged links for downloads; managers cannot download or export.
  • An append-only audit log of sensitive actions, readable by org admins; staff console access logged in a log org admins can read.
  • Console access only for listed platform staff, with two-factor sign-in, and console actions only through server functions no client role can call.
  • API tokens stored only as hashes; webhook secrets kept in a private schema; outgoing webhooks signed; private addresses refused.
  • Rate limits on every public route; security headers including a per-request content security policy.
  • Committed secrets refused by a pre-commit check; dependencies pinned and checked for advisories.
  • Nightly backup of recordings to a separate provider; deletions reach the backup.
  • An incident response plan with named roles; breach notice as section 10 states.

Annex 3: Subprocessors

The current list, with purpose, data and location: truesit.ai/legal/subprocessors.