Draft — under legal review. This page is a working draft awaiting legal review, and the wording may change before it takes effect.

Provider: TodsAI LLC

Data Processing Agreement

Last updated: September 25, 2026

This page summarises the data processing terms that apply between an agency using Nelxa (the controller) and TodsAI LLC (the processor). The signed agreement is available on request at hello@nelxa.com; where this summary and the signed agreement differ, the signed agreement prevails.

1. Subject matter and duration

We process personal data on the agency's behalf to provide the Nelxa service, for as long as the agency's workspace exists and until the data is deleted or returned afterwards.

2. Nature and purpose

Hosting, storage, display, transmission (emails, PDFs, portal pages, payment links), automation and, where the agency enables it with its own key, AI-assisted drafting and parsing. All processing follows the agency's documented instructions, which are given through the product's settings and features.

3. Data subjects and categories

Data subjects: the agency's travellers and their fellow passengers, business contacts and suppliers, and the agency's own staff.

Categories: identification and contact data; identity document details; travel and booking data; financial data (instalments, payments, refunds); contract and signature records; communications; and, where the agency records them for group passengers, dietary and medical notes and emergency contacts.

4. Our obligations

We process data only on instruction; keep it confidential and bind our staff to confidentiality; apply the security measures below; assist the agency with data subject requests and with its security and impact assessment duties; notify the agency without undue delay of a personal data breach affecting its data; delete or return the data at the end of the service; and make available the information needed to demonstrate compliance.

5. Security measures

Tenant isolation by row-level security in PostgreSQL and per-request authorisation in the application; encryption in transit; encryption at rest of provider keys (AES-256-GCM); server-controlled, per-agency file paths; expiring personal links and rate-limited one-time codes for travellers; role-based access for staff; recoverable deletion with a 30-day purge; logging of automation runs and signatures; build-time checks that refuse code reading across agencies.

6. Sub-processors

We use the sub-processors listed below. We will inform account owners before adding or replacing a sub-processor that processes agency data, so the agency can object. Services the agency connects with its own account (Stripe, email providers, AI providers, Google Calendar) act on the agency's own contract with them.

ProviderPurposeLocationWhen
SupabasePostgreSQL database hostingFrankfurt, Germany (EU)Always
Google Cloud (Firebase App Hosting, Cloud Run)Application hosting and PDF renderingeurope-west4, Netherlands (EU)Always
StripeCard payments through the agency's own Stripe accountEU / USA, per Stripe's termsWhen the agency connects it
Brevo, Resend or the agency's SMTP serverSending emails to travellersPer the provider the agency choosesWhen the agency connects it
OpenAI, Anthropic or Google AIOptional AI features, with the agency's own key, only for content the agency submitsPer the provider the agency choosesWhen the agency connects it
Google (Calendar API)Calendar sync for staff who connect itPer Google's termsWhen the agency connects it
AeroDataBox, Google Places, Unsplash, Pexels, PixabayLookups of flight numbers, places and stock photos (search terms only)Per each provider's termsWhen the feature is used
Firebase Authentication (Google)Staff sign-inGlobal Google serviceAlways
Firebase Storage (Google)Uploaded files (documents, logos)European UnionAlways

7. Deletion and return

The agency can delete records at any time (trash, purged after 30 days) and can export the group manifest as CSV; Premium workspaces can export financial records as CSV. At the end of the service we delete the workspace data or, on request, return it in a machine-readable form first, except where the law requires retention.

8. Audits

We answer reasonable written audit questions and make available documentation of our measures. On-site audits are agreed case by case in the signed agreement.

Questions about this document: hello@nelxa.com.

TodsAI LLC · todsai.com · hello@nelxa.com