Legal

Data processing agreement

Last updated 15 October 2026

This agreement is part of the terms of service between Belline Technologies Limited ("Belline", "we") and the business that uses Belline ("the Customer", "you"). It applies whenever we process personal data about the Customer's own customers on the Customer's behalf, which is what Belline does when it answers the Customer's calls and messages. How we handle the Customer's own account details, and visits to our website, is in the privacy policy instead.

1. Words used here

• Customer Personal Data: personal data about the people who contact the Customer through Belline, or who are named in what they say, that we process for the Customer under the terms.
• Data protection law: the DIFC Data Protection Law (DIFC Law No. 5 of 2020), which governs Belline, and any other data protection law that applies to the Customer's processing, which may include the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), the GDPR, the UK GDPR or the Swiss Federal Act on Data Protection.
• Sub-processor: a company Belline engages that processes Customer Personal Data for Belline. The current ones are in Annex 3.
• A connection of the Customer's own: a service the Customer connects under its own account and contract, such as its calendar, its CRM or its Slack. Belline sends data to it on the Customer's instruction; it is the Customer's provider, not Belline's Sub-processor.

2. Who decides

For Customer Personal Data the Customer is the controller and Belline is its processor. Where the Customer itself acts for another controller, such as a group company, Belline is a sub-processor and the Customer confirms that its instructions are authorised by that controller. For the Customer's account, billing, security records and website visits, Belline decides, and the privacy policy applies.

3. What is processed (Annex 1)

4. What the Customer is responsible for

4.1 The lawfulness of the processing it instructs: having a lawful basis, giving its customers the notices the law requires, including that they may be talking to an automated assistant and that what they say is turned into text, and obtaining any consent the law requires.

4.2 Giving Belline only personal data it is entitled to give.

4.3 The accuracy of the information it gives Belline, and the security of its own accounts, its users and its own connections.

4.4 Health and other sensitive data. A clinic or other health business must set Belline up to collect only what it needs to make or manage an appointment, and must not instruct Belline to collect clinical information. It is the Customer's responsibility to decide whether health-data rules apply to it, including the UAE's law on health data (Federal Law No. 2 of 2019), and whether the locations in Annex 3 are allowed for that data. Belline does not offer processing that stays inside the UAE (section 8).

5. What Belline commits to

5.1 Instructions. We process Customer Personal Data only on the Customer's instructions: the terms and this agreement, the way the Customer sets Belline up, and any other written instruction we agree. If we believe an instruction breaks data protection law we will say so. If the law requires us to process it otherwise, we will tell the Customer first, unless the law forbids that.

5.2 No other use. We do not sell Customer Personal Data, use it for advertising, or use it to train AI models. We may count things in ways that identify neither the Customer nor any person, to run and improve Belline.

5.3 Confidentiality. The people at Belline who can reach Customer Personal Data are bound to keep it confidential, and look at it only to provide, support or secure Belline, when the Customer asks us to help, or when the law requires it.

5.4 Security. We keep the measures in Annex 2 in place. We may change them, but not in a way that lowers the protection overall.

5.5 Records. We keep a record of the processing we carry out for our customers, as data protection law requires.

5.6 Assessments. We help with the Customer's data protection impact assessments and any consultation with its regulator, as far as the information we hold allows, including by providing this agreement and its annexes.

6. Requests from the people concerned

6.1 Every conversation, request and booking is in the Customer's dashboard, so the Customer can see what we hold about a person. We will help the Customer correct, export or delete it when asked.

6.2 If somebody asks us directly about data we hold for a Customer, we will not answer the substance ourselves. We will pass the request to the Customer within 5 business days, or, where the person has not said which business they contacted, make reasonable efforts to find out.

7. Sub-processors

7.1 Authorisation. The Customer authorises Belline to engage Sub-processors. The current ones are in Annex 3, which follows what is switched on: a company that no Customer's data can reach is not listed.

7.2 The same obligations. We hold each Sub-processor to data protection obligations no less protective than these, as far as they apply to what it does, and we remain responsible for its performance as data protection law requires.

7.3 Notice. We update Annex 3 before a new Sub-processor starts processing Customer Personal Data. Where it will process the data of every Customer, we also tell account holders by email at least 14 days before.

7.4 Emergencies. If a Sub-processor has to be replaced urgently for security, legal or continuity reasons, we may do it straight away and tell the Customer as soon as we can afterwards. The right to object below still applies.

7.5 Objecting. The Customer may object on reasonable data protection grounds, in writing, within the notice period. We will discuss it in good faith. If we cannot offer a reasonable alternative, such as not using the feature concerned, the Customer may end the affected part of the service and have what it paid in advance for the unused period refunded.

7.6 The Customer's own connections are not Sub-processors. When the Customer connects its own calendar, CRM, Slack or booking system, the data Belline sends there goes to a provider the Customer has its own contract with. We are responsible for the security of the connection and of the credentials on our side. They are listed in Annex 3 for transparency.

8. Where the data goes

8.1 Locations. Belline is established in the Dubai International Financial Centre. Nothing Belline uses runs in the UAE: Customer Personal Data is processed where each Sub-processor in Annex 3 processes it, which is mainly the United States. Where the location of one is not recorded, Annex 3 says so rather than guess.

8.2 Safeguards. Transfers outside the Dubai International Financial Centre rely on the standard data protection clauses in each provider's own data processing terms, which Belline is putting in place with each of them.

8.3 Customers subject to European law. Where the Customer is subject to the GDPR, the UK GDPR or the Swiss Federal Act on Data Protection and asks for them, the parties will enter into the standard contractual clauses approved by the European Commission (Module Two, or Module Three where the Customer is itself a processor), with the UK Addendum or the Swiss amendments where they apply.

8.4 Health data in the UAE. The UAE's law on health data restricts storing or processing health data about health services provided in the UAE outside the UAE, with exceptions. Because Belline does not offer processing that stays inside the UAE, a Customer that law applies to must not use Belline to process health data unless it is satisfied that an exception applies.

9. Personal data breaches

9.1 We tell the Customer about a personal data breach affecting Customer Personal Data without undue delay after we become aware of it, and in any event within 48 hours.

9.2 As far as we know it at the time, and adding to it as we learn more, the notice says what happened, which kinds of data and roughly how many people and records are affected, the likely consequences, what we have done or will do, and who to contact.

9.3 We contain, investigate and limit the breach, and help with the Customer's notices to its regulator and to the people affected. We do not notify the Customer's regulator or customers on its behalf unless it asks us to or the law requires it.

9.4 The notice goes to the account owner's email address. Notifying a breach is not an admission of fault.

10. Showing that we keep to this

10.1 Once a year, or after a breach or at a regulator's request, the Customer may ask in writing for the information reasonably needed to show that we keep to this agreement, such as answers to a security questionnaire and summaries of our policies.

10.2 If that is not enough, or a regulator requires it, the Customer or an independent auditor bound by confidentiality, who is not our competitor, may audit us on at least 30 days' notice, during business hours, without access to other customers' data, and at the Customer's cost.

10.3 Belline holds no third-party security certification.

11. Handing back and deleting

11.1 While the account is open, the Customer can ask us to delete specific records at any time.

11.2 When the account closes, we hand the Customer's data over on request and delete it within 90 days, except records the law requires us to keep, which we keep confidential and use for nothing else. On request, we confirm the deletion in writing.

11.3 Data in the Customer's own connections, such as the events Belline wrote into its calendar, stays there: it is the Customer's. Where a Sub-processor keeps data under its own retention rules, we ask it to delete it or use its shortest setting where it offers one.

12. Liability

Liability under this agreement is subject to the limits in the terms of service, except where data protection law does not allow a limit.

13. General

This agreement lasts as long as we process Customer Personal Data for the Customer. If data protection law changes, or a regulator or court issues binding guidance, we may change this agreement on 30 days' notice by email as far as needed to comply, without lowering the protection it gives. It is governed by the same law as the terms of service. It is published in English, and the English text governs.

Annex 2: How we protect the data

• Card details are entered in Stripe's own form and never reach Belline.
• Passwords are stored as salted hashes (scrypt). Sessions are held on the server and can be revoked; their cookies are httpOnly, Secure and SameSite.
• Credentials for the Customer's connected services are stored encrypted (AES-256-GCM) and never shown back in a browser.
• Each person signed in to a Customer's account sees only the locations they are given, and what they can change depends on their role. Every change to Belline is checked automatically for one Customer reaching another's data.
• Personal data is taken out of application logs.
• Backups are encrypted before they are stored, and kept off-site.
• Belline's website and app send a Content Security Policy and HSTS, and data travels to and from them encrypted.
• The language model answers from the information the Customer approved; whether a time is free, and whether a booking is made, come from the booking system or calendar, not from the model.
• A written breach procedure and a breach register.

Annex 3: Sub-processors

The companies that process Customer Personal Data for Belline, what each one does, and where it processes data as far as Belline has recorded it (each as the company itself publicly states it). Companies that only ever see the Customer's own account and billing details, or visits to our website, such as Stripe, are named in the privacy policy instead. Transfers rely on the standard data protection clauses in each provider's own terms, which Belline is putting in place with each of them.

The Customer's own connections

Not Sub-processors (section 7.6): services the Customer connects under its own account, listed only while Belline can connect them.

Contact

Belline Technologies Limited · IH-00-01-03-OF-05, Level 3, Innovation One, Dubai International Financial Centre, Dubai, United Arab Emirates · hello@belline.ai