What it says
What this says
Current to 11 Oct 26Executed Data Processing Agreement, effective 16 Jan 2026, making Wexmoor the controller and B-Brain the processor. It sets no price, availability or response-time figures. It allows general sub-processor authorisation and incident notice without undue delay.
What it is: an executed DPA under the master agreement and order form, signed on 16 Jan 2026 by Jordan Pike for B-Brain and an unnamed authorised signatory for Wexmoor. It states "B-Brain processes Personal Data only to provide the Services".
Commits: B-Brain to notify of a Security Incident "without undue delay", give notice of new Sub-processors, and delete Personal Data held outside the Customer's account on termination. Wexmoor stays responsible for the access controls of its Snowflake account.
Unusual: the Customer is in the United States and B-Brain in the United Kingdom, so transfers rely on "a lawful transfer mechanism recognised under Data Protection Laws" without naming one. Audit is on reasonable notice.
Not settled: no price, term length, renewal date, service levels or connector dates appear. The signing customer individual is not named, so their seniority is unknown. The text does not name the sub-processors or the transfer mechanism.
As found in this document
Current to 9 Oct 26- Date signed16 Jan 2026Source: object_read:doc_010_006
- Date start16 Jan 2026Source: object_read:doc_010_006
- Security Incident notificationB-Brain will notify the Customer without undue delay after becoming aware of a Security Incident affecting Personal DataB-Brain will notify the Customer without undue delay after becoming aware of a Security Incident affecting Personal Data · Source: object_read:doc_010_006
- Sub-processor noticegive the Customer reasonable notice of any new Sub-processor, so that the Customer may object on reasonable data protection groundsgive the Customer reasonable notice of any new Sub-processor, so that the Customer may object on reasonable data protection grounds · Source: object_read:doc_010_006
- Return and deletionB-Brain will remove the brain components it operates and delete any Personal Data it holds outside the Customer's account, unless the law requires it to keep itB-Brain will remove the brain components it operates and delete any Personal Data it holds outside the Customer's account, unless the law requires it to keep it · Source: object_read:doc_010_006
- Individual rights requestspass the request to the Customer without undue delaypass the request to the Customer without undue delay · Source: object_read:doc_010_006
- Auditon reasonable notice, during business hours and no more often than is reasonably necessaryon reasonable notice, during business hours and no more often than is reasonably necessary · Source: object_read:doc_010_006
The document
Body
Unusual terms
Current to 9 Oct 26- General sub-processor authorisation
- Cross-border transfer UK to US
- DPA prevails over master agreement on personal data