Legal

Data Processing Agreement

Last updated: September 8, 2026Effective: September 8, 2026

This Data Processing Agreement (the "Agreement") is entered into between you (as the controller of the business data, the "Customer") and MODELGO PTE. LTD. (as the processor acting on the Customer's instructions, "ModelGo", "we", "us") and governs our processing of business data (which may contain personal data) on your behalf when you use the ModelGo website, console, API, CLI, SDK, model gateway and related services. This Agreement forms part of the Terms of Service and any related contract between you and us.

Key points

Under this Agreement, the Customer determines the purposes and means of processing its business data and is the controller; ModelGo processes such data on the Customer's instructions and in accordance with the contract, and is the processor.
The Customer shall ensure that business data submitted to the services or processed through the API has been lawfully and sufficiently authorised and has a valid legal basis for processing. Where personal data, sensitive personal data or cross-border transfers are involved, the Customer shall complete the necessary notices, consents and compliance assessments.
This Agreement should be read together with the Terms of Service and the Privacy Policy. In the event of a conflict on data processing matters, this Agreement prevails unless otherwise agreed. Actual product capabilities, retention policies and regional routing are as set out in the console and the contract.

1. Definitions and Roles of the Parties

"Business data" means the input, output, prompts, files, logs and related data submitted or uploaded to the services by the Customer and its authorised users through the console, API, CLI, SDK or model gateway, or processed or generated by the services.
"Personal data" means any information relating to an identified or identifiable natural person, recorded electronically or otherwise; "processing" includes collection, storage, use, adaptation, transmission, provision, disclosure and deletion.
In respect of personal data contained in business data, the Customer determines the purposes and means of processing and acts as the controller; ModelGo processes such data only within the scope entrusted by the Customer and on the Customer's instructions, and acts as the processor.

2. Purpose, Scope and Means of Processing

We process business data solely to provide and maintain the services, including model calls and routing, content safety auditing, caching, billing and usage statistics, logging and troubleshooting, security protection and compliance with legal obligations.
The means of processing include transmission within the gateway and infrastructure, temporary retention or retention as configured, reading and analysis within the necessary scope, and transmission of requests to the corresponding model providers and cloud infrastructure as selected by you or routed by the system.
Without the Customer's instruction or a legal requirement, we do not use business data for purposes beyond this Agreement, and we do not use it to train our own models. Training and retention rules of third-party model providers are governed by their own terms; see Section 8.

3. Types of Data and Data Subjects

The types of data processed typically include: prompts and input content you submit, output content returned by models, uploaded documents or multimodal files, account and key identifiers, and call metadata (timestamp, model, tokens, status code, request ID and similar).
The categories of data subjects involved are determined by the Customer's business scenarios and may include the Customer's employees, end users or business counterparties. The Customer is responsible for the lawfulness of the categories of subjects and types of information contained in its business data.
The Customer should not submit sensitive personal data without a valid legal basis. Where such processing is genuinely required, the Customer shall obtain separate consent and implement the necessary protective measures.

4. Customer's Rights and Obligations

The Customer is entitled to give us lawful and clear instructions regarding processing, and may configure log retention, privacy mode, sampling, regional routing, key permissions and budget policies within the available product capabilities.
The Customer shall ensure that business data has a lawful source and sufficient authorisation, that processing has a valid legal basis, and that notice and consent obligations towards data subjects have been fulfilled. The Customer bears liability arising from unlawful data or insufficient authorisation.
The Customer shall keep its account and API Keys secure and is responsible for processing activities initiated using its account and keys.

5. ModelGo's Rights and Obligations

We process business data in accordance with this Agreement and the Customer's instructions and do not exceed the necessary scope. We do not change the purposes or means of processing except as required by law or as further instructed by the Customer.
We are under an obligation of confidentiality in respect of business data that comes to our knowledge during processing, and we require employees and partners who access such data to observe equivalent confidentiality and security requirements.
If we consider that a Customer instruction infringes laws or regulations, we will inform the Customer promptly and may suspend the relevant processing where necessary.

6. Confidentiality

Each party shall keep confidential the other party's trade secrets, business data and other confidential information obtained in performing this Agreement, and shall not disclose it to third parties without the other party's consent, except as required by law or otherwise provided in this Agreement.
Personnel who access business data shall be authorised on a least-privilege and need-to-know basis and are subject to access controls, log auditing and similar measures.

7. Technical and Organisational Security Measures

We implement security measures appropriate to the risk, including encryption in transit and at rest, access control and least privilege, key and credential management, network and gateway protection, content safety guardrails, and operation and access log auditing.
We apply change management, monitoring and alerting to production systems and assess and improve our security capabilities periodically. Specific measures may be adjusted in line with technical developments and compliance requirements.
The Customer shall implement corresponding security measures on its side (such as key custody, access permission management and source IP restrictions) so that both parties' measures together safeguard data security.

8. Sub-processors and Model Providers

To provide the services, we may engage model providers, cloud infrastructure, payment, sign-in and monitoring providers as sub-processors. The relevant requests and outputs may be transmitted to the model provider and infrastructure you select or that the system routes to.
Model providers and infrastructure may each apply their own rules on data retention, use for training, regional routing, content safety and log retention. We will endeavour to explain the available options through product configuration, documentation or the contract; their own terms govern those rules.
We require sub-processors to assume data protection obligations no less protective than those in this Agreement. Where a material change of sub-processor occurs, we will provide the corresponding information through the product or the contract.

9. Assisting the Customer with its Obligations

To the extent technically feasible and reasonable, we will assist the Customer through product capabilities in responding to data subject requests for access, copies, correction and deletion, and will cooperate with the Customer in carrying out necessary compliance assessments.
If we receive a request made directly to us by a data subject concerning the Customer's business data, we will generally refer it to the Customer or cooperate under the Customer's instructions, unless the law requires otherwise.

10. Storage, Cross-border Transfers and Regional Routing

Retention periods for business data are determined by product configuration, the contract and legal requirements. Data held beyond the necessary period will be deleted or anonymised, unless laws or regulations provide otherwise.
Some model providers or infrastructure may be located in different regions, and using those capabilities may involve cross-border transfers of data. Whether such capabilities are enabled and how routing is configured is chosen by the Customer within the available product capabilities, and the Customer is responsible for assessing and fulfilling the related cross-border compliance obligations.

11. Security Incident Notification

In the event of a security incident involving business data, such as leakage, alteration or loss of personal data, we will take remedial measures as required by laws and regulations and notify the Customer within a reasonable time through the means agreed in the contract.
The notification will generally include the basic circumstances of the incident, its likely impact, and the measures taken or to be taken, so that the Customer can fulfil its own obligations as controller.

12. Data Handling after Termination

Upon termination of the services or at the Customer's request, we will return or delete the relevant business data in accordance with the Customer's instructions and the available product capabilities. Where laws or regulations require continued retention, we will continue to fulfil our protection obligations during the retention period.
Data on backup media will be overwritten or deleted within its normal rotation cycle.

13. Audit and Compliance

Subject to confidentiality requirements and without compromising the data security of other customers, we will assist the Customer in verifying our performance of this Agreement by reasonable means, such as providing compliance descriptions, security capability materials or third-party audit reports.
Where an on-site or additional audit is required, the parties shall separately agree on its scope, method, frequency and costs.

14. Changes, Effectiveness and Contact

We may update this Agreement in response to laws and regulations, regulatory requirements or changes to the services, and will publish the update on our website or through product channels. The updated version takes effect from the date of publication or as agreed. If you object to a change, you may stop using the relevant services.
If you have any questions, comments or complaints regarding this Agreement or data processing matters, you may contact us through the contact channels published on our website or through your commercial or customer support channel.