Data Processing Agreement

Last updated: March 12, 2026

1. Definitions

In this Data Processing Agreement (“DPA”):

  • “Controller” means you, the customer, who determines the purposes and means of processing Personal Data through Echosaw.
  • “Processor” means Orange Sky Software Inc. (“Orange Sky”), which processes Personal Data on behalf of the Controller through the Echosaw Media Intelligence product.
  • “Personal Data” means any information relating to an identified or identifiable natural person that is processed by Echosaw in connection with the services.
  • “Processing” means any operation performed on Personal Data, including collection, storage, analysis, retrieval, transmission, and deletion.
  • “Sub-processor” means a third party engaged by Orange Sky to process Personal Data on behalf of the Controller.

This DPA supplements the Terms of Service, Privacy Policy, and Data Retention and Deletion Policy and applies where Orange Sky processes Personal Data on your behalf.

2. Scope and Purpose of Processing

Orange Sky processes Personal Data only as necessary to provide the Echosaw services you have subscribed to, including media analysis, transcription, report generation, and related intelligence outputs. The types of Personal Data processed may include:

  • Audio and video content containing voices, images, or identifying information of individuals
  • Metadata associated with submitted media (file names, timestamps, locations where embedded)
  • Account information (email addresses, names, organization details)
  • Usage and access logs generated through Product interaction

Processing is performed solely in accordance with your instructions and applicable law. We do not process Personal Data for our own independent purposes except as required for platform security, billing, and legal compliance.

3. Sub-processors

Orange Sky uses the following categories of sub-processors in connection with Echosaw:

  • Cloud Infrastructure: Amazon Web Services (AWS) for compute, storage, and data processing
  • AI/ML Services: AWS Bedrock (Amazon Titan, Anthropic Claude) for analysis and intelligence generation
  • Payment Processing: Stripe for subscription billing and payment handling
  • Authentication: Amazon Cognito for user identity and session management

We maintain contractual agreements with all sub-processors requiring them to protect Personal Data to a standard no less protective than this DPA. We will notify you of any material changes to our sub-processor list via email or posting on the Site and provide you a reasonable opportunity to object.

4. Security Measures

Orange Sky implements appropriate technical and organizational measures to protect Personal Data, including:

  • Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
  • Access controls with role-based permissions and least-privilege principles
  • Regular security assessments and vulnerability monitoring
  • Secure deletion procedures as described in our Data Retention and Deletion Policy
  • Incident response procedures with prompt notification obligations
  • Employee access limited to authorized personnel with confidentiality obligations
5. Data Subject Rights

Orange Sky will assist you in responding to data subject requests (access, rectification, erasure, portability, restriction, or objection) to the extent required by applicable data protection law. If we receive a request from a data subject directly, we will promptly redirect the request to you unless legally required to respond directly.

6. Data Breach Notification

In the event of a Personal Data breach, Orange Sky will notify you without undue delay (and in any event within 72 hours of becoming aware of the breach) with sufficient detail to allow you to meet your own notification obligations under applicable law.

7. International Transfers

Echosaw services are hosted and processed in the United States. Where Personal Data is transferred from the European Economic Area (EEA), United Kingdom, or Switzerland, such transfers are made in compliance with applicable data protection law, including through the use of Standard Contractual Clauses (SCCs) or other lawful transfer mechanisms.

8. Audit Rights

Upon reasonable request and subject to appropriate confidentiality obligations, Orange Sky will make available information necessary to demonstrate compliance with this DPA. We may satisfy audit requests through third-party audit reports, certifications, or documented responses to reasonable inquiries.

9. Term and Termination

This DPA remains in effect for the duration of your use of Echosaw. Upon termination of your subscription, we will delete or return Personal Data in accordance with our Data Retention and Deletion Policy unless retention is required by applicable law.

10. Contact

Questions about this Data Processing Agreement?

Service Provider
Orange Sky Software, Inc.
Full Address
Orange Sky Software, Inc.
779 Port Leon Dr. #691
St. Marks, FL 32355