AlpacaKeep1. Parties and effect
The controller is the person or organisation responsible for the farm workspace identified in the AlpacaKeep account (Customer). The processor is Devid Demetz, Larciunei 46, 39048 Selva di Val Gardena (BZ), Italy (AlpacaKeep). A member accepting this Agreement for a farm confirms that they are authorised to bind the Customer.
This Agreement takes effect when the Customer accepts the Terms of Service that incorporate it, and continues while AlpacaKeep processes Customer Personal Data. It satisfies the written-contract requirement in GDPR Article 28 and applies alongside the Terms. Definitions in the GDPR have the same meaning here. Where the UK GDPR applies to the Customer's processing, references in this Agreement to the GDPR include the corresponding provisions of the UK GDPR and the Data Protection Act 2018, and this Agreement is also the contract required by Article 28 of the UK GDPR. Where the Customer is in New Zealand or Australia, this Agreement also sets the terms on which AlpacaKeep holds the Customer's records for it.
2. Processing details
The following details describe the processing entrusted to AlpacaKeep:
- Subject matter: Operation of the AlpacaKeep herd-management service and the features the Customer chooses to use.
- Duration: The account term and the deletion periods described in Section 9, unless law requires longer retention.
- Nature and purpose: Hosting, organising, retrieving, displaying, exporting, backing up and deleting farm records; sharing them with authorised farm members; when requested, using AI to read a certificate and prepare a draft pedigree for human review; and, for a farm in the closed test of Ask your herd, using AI to answer an authorised user's question from read-only lookups of that farm's records, with an optional web search built only from the question and the farm's country. The AI does not certify the document, and it does not save or change farm records without a user action.
- Personal-data types: Farm-member names and contact details; contacts, breeders, previous owners, buyers, sellers, veterinarians and suppliers; correspondence and notes; financial records; photos, signatures and documents; certificate images or PDFs; animal and ancestor identifiers linked to people; questions typed by users and the answers generated for them; and security, support and audit metadata.
- Data subjects: The Customer, farm members, employees and contractors, and people recorded by the Customer such as breeders, owners, buyers, sellers, veterinarians, suppliers and other contacts.
3. Documented instructions
AlpacaKeep processes Customer Personal Data only on documented instructions from the Customer, including the Terms, this Agreement, settings, support requests and actions taken by authorised users. An instruction to use a feature includes the processing reasonably necessary to provide that feature and the transfers disclosed in this Agreement.
AlpacaKeep will inform the Customer before processing required by Union or Member State law or, where the UK GDPR applies, by the law of the United Kingdom, unless the law prohibits notice. AlpacaKeep will promptly tell the Customer if an instruction appears to infringe data-protection law and may suspend that instruction while the parties resolve it.
When the Customer asks AlpacaKeep for help, an authorised user who manages the farm's team (the Owner or a Co-Owner) may give AlpacaKeep support access to the farm for a limited period (3, 7, 14 or 30 days) and at a level the Customer chooses; access that includes financial records and settings can be given by the Owner only. AlpacaKeep may ask for such access, but does not access a farm until an authorised user of that farm allows it. Giving or allowing access is a documented instruction under this section and is recorded with who gave it, the level and its end. AlpacaKeep uses the access only for what the Customer asked, through a dedicated support account protected by a second sign-in factor; the access ends by itself on the date shown, any authorised user who manages the team can end it earlier, and every action taken under it is shown in the farm's activity log under "AlpacaKeep support". Support access never allows AlpacaKeep to change the farm's team, give a consent or permission in the Customer's name, publish the Customer's data or become the owner of the farm.
When the Customer asks AlpacaKeep in writing to bring the farm's records across from another system or from files the Customer sends, that written request is a documented instruction for that import: AlpacaKeep imports only the records sent for that purpose, only into that farm, and tells the Customer when the import is done. Where the import is carried out through support access, the preceding paragraph also applies.
3b. Ask your herd: reading the farm's questions, on the Customer's permission
When the Customer's Owner or a Co-Owner allows sharing for the farm on the Ask your herd page, the Customer gives AlpacaKeep specific permission, recorded with who gave it, its time and the wording shown, to read the questions that the farm's authorised users ask from then on, and their answers, for AlpacaKeep's own purpose of finding wrong answers and improving the feature. For that use AlpacaKeep is a controller in its own right, not the Customer's processor (GDPR Article 28(10)). While sharing is allowed, AlpacaKeep tells the farm's other authorised users on the Ask your herd page that the farm shares its questions. The permission counts only while the person who gave it is an Owner or Co-Owner of the farm.
For that use AlpacaKeep will:
- read a shared question only while it is kept (30 days) and without the farm's name or the user's identity being shown, and record each time it opens the shared questions in its access log;
- not use shared questions to train machine-learning models, not disclose or sell them, and not copy them out of the Service unless names and anything that identifies the farm have been removed first;
- record each choice of the Customer with who made it, the time and the version of the wording shown.
The Customer may withdraw the permission at any time: by switching sharing off on the Ask your herd page, which stops all reading under this section at once, or by writing to AlpacaKeep, which then switches it off without undue delay and at the latest within two working days. From then on AlpacaKeep reads none of the farm's questions under this section, unless the permission is given again, and then only questions asked after that.
4. Confidentiality and security
AlpacaKeep ensures that people authorised to process Customer Personal Data are bound by confidentiality and access it only as needed. Measures appropriate to the risk include:
- Encryption in transit using TLS and encryption at rest through the hosting providers.
- Tenant isolation through database row-level security and farm roles.
- Server-only storage of privileged provider keys and restricted administrative access.
- Logging, monitoring, tested deletion workflows and an incident-response procedure.
- Backups, change control, dependency review and recovery procedures appropriate to the service.
- Regular review of technical and organisational measures, taking account of the state of the art, implementation cost, processing context and risk.
Read the current security measures and responsible-disclosure policy.
5. Sub-processors
The Customer gives AlpacaKeep general written authorisation to use the sub-processors on the public Sub-processors page for the purposes stated there. The list includes Anthropic Ireland, Limited for the Claude API. Anthropic receives certificate content only when the AI reader is enabled and an authorised user submits a document, and receives a farm's records for Ask your herd only while that farm takes part in its closed test and an authorised user asks a question. For such a farm, the owner's written agreement to take part in the test is also the Customer's specific written authorisation for Anthropic to process the farm's records for that purpose. Anthropic engages its own sub-processors, including for web search, under its Data Processing Addendum; Anthropic publishes and changes that list on its own notice terms, and the Sub-processors page links to it.
AlpacaKeep will give active-account customers at least 30 days advance notice by email before adding or replacing a sub-processor that will process Customer Personal Data. The notice will identify the provider, activity and location. The Customer may object during that period on reasonable data-protection grounds. AlpacaKeep will seek a reasonable alternative; if none is available, the Customer may stop using the affected feature or terminate the affected service and receive a pro-rata refund of prepaid fees for the unused period.
AlpacaKeep requires each sub-processor by written contract to provide the protection required by applicable data-protection law and remains responsible to the Customer for the sub-processor obligations it has entrusted.
View the current sub-processor list, locations, purposes and transfer safeguards.
6. International transfers
Primary application data is stored in Frankfurt, Germany. If a sub-processor handles Customer Personal Data outside the EEA, AlpacaKeep uses an applicable adequacy decision, the European Commission Standard Contractual Clauses or another lawful safeguard described on the Sub-processors page. Where the UK GDPR applies, UK law permits the storage of Customer Personal Data in the EEA, and for a transfer outside the United Kingdom and the EEA AlpacaKeep relies on UK adequacy regulations, the UK International Data Transfer Addendum to the Standard Contractual Clauses, the UK International Data Transfer Agreement or another safeguard permitted by the UK GDPR.
The Claude API stores the content of each AI request (a submitted certificate, or a question with the farm records looked up to answer it) in the United States and may process it in any region Anthropic uses. Anthropic processes that content under its Data Processing Addendum, which includes the EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914). Web searches for Ask your herd are run by Anthropic's own sub-processors in the United States. The Claude API does not provide EU residency. AlpacaKeep will move to a route with EU residency before it commits to EU-only AI processing.
Where the Customer is established in a country without an adequacy decision of the European Commission, such as Australia, the Standard Contractual Clauses adopted by Commission Implementing Decision (EU) 2021/914, Module Four (transfer processor to controller), are incorporated into this Agreement for AlpacaKeep making Customer Personal Data available to the Customer, with AlpacaKeep as data exporter and the Customer as data importer. For those clauses, Annex I is completed by the parties in Section 1 and the details in Section 2 of this Agreement, the transfer is continuous for as long as the Customer's account exists, and no special categories of personal data are transferred; the optional Clause 7 does not apply; under Clause 17 the clauses are governed by the law of Italy, and under Clause 18 disputes arising from them are resolved by the courts of Italy.
7. Assistance to the Customer
Taking account of the nature of the processing and the information available, AlpacaKeep will provide reasonable assistance with:
- Requests to access, correct, erase, restrict or export Customer Personal Data, and objections relating to it.
- Security duties under GDPR Article 32 and personal-data-breach duties under Articles 33 and 34.
- Data protection impact assessments and prior consultation under Articles 35 and 36.
- Information reasonably needed for the Customer to demonstrate compliance with Article 28.
8. Personal-data breaches
AlpacaKeep will notify the Customer without undue delay after becoming aware of a personal-data breach affecting Customer Personal Data. Notice will include the known nature and scope, likely consequences, measures taken or proposed, and a contact for follow-up. Information may be supplied in stages when it is not available at once.
AlpacaKeep will take reasonable steps to contain, investigate and remedy the breach. The Customer remains responsible for deciding whether and how to notify a supervisory authority or affected data subjects, with AlpacaKeep providing the assistance described above.
9. Return, export and deletion
The Customer can export supported farm records during the account term. On account deletion, AlpacaKeep deletes Customer Personal Data after the stated 30-day deletion period and instructs its sub-processors to delete or return the data as applicable, unless Union or Member State law or, where the UK GDPR applies, the law of the United Kingdom requires retention. Financial and audit records may be retained only for the applicable legal period and access remains restricted.
Uploaded documents remain until the Customer deletes them or the account is erased. Unapplied AI proposals and issue data expire after 30 days. Applied proposal details are cleared after 90 days while the minimal audit link is retained. Questions to Ask your herd and their answers are visible only to the user who asked, and to AlpacaKeep only where the Customer allows it (Section 3b), and are deleted after 30 days, or earlier when that user clears them; a record without them is deleted 180 days later. Provider-side retention follows the provider terms disclosed on the Sub-processors page: Anthropic deletes API inputs and outputs within 30 days and may keep content flagged under its Usage Policy for up to 2 years.
10. Information and audits
AlpacaKeep will make available the information reasonably necessary to demonstrate compliance with this Agreement, including relevant policies and independent provider reports that AlpacaKeep is permitted to share.
The Customer may request an audit no more than once in any 12-month period on reasonable advance notice, unless a breach, supervisory-authority request or credible compliance concern justifies another audit. Audits must protect other customers, security and confidential information and should use available reports before requiring an inspection.
11. Customer responsibilities
The Customer is responsible for its controller obligations and agrees to:
- Have a lawful basis for the personal data it places in AlpacaKeep and issue any notices required by GDPR Articles 13 and 14.
- Give lawful, clear instructions and avoid entering data that is unnecessary for herd management.
- Ensure that farm members are authorised, keep credentials secure and configure permissions appropriately.
- Respond to data-subject and supervisory-authority requests for which the Customer is responsible.
12. Term, precedence and changes
This Agreement ends when AlpacaKeep has deleted all Customer Personal Data required to be deleted under Section 9. Duties that by their nature continue after termination remain in effect.
If this Agreement conflicts with the Terms on processing Customer Personal Data, this Agreement controls. Mandatory data-protection law controls over both.
Material changes follow the notice procedure in the Terms. Changes to sub-processors follow Section 5. This Agreement is governed by the law and jurisdiction provisions in the Terms without limiting rights under applicable data-protection law.
13. Privacy contact
Questions, instructions and audit requests under this Agreement should be sent to privacy@alpacakeep.com.