Data Processing Agreement
In short: This agreement governs how TrimCI processes personal data contained in your CI pipeline data on your organization's behalf, as required by Article 28 GDPR. It applies automatically to every organization — accepted together with the Terms of Service at registration, no signature needed. Everything stays in the EU, the AI runs on our own servers, and when you delete your organization, its data is deleted.
1. Parties, purpose and scope
This Data Processing Agreement ("DPA") is concluded between the customer organization using the TrimCI service (the "Customer", acting as controller) and Bogusław Chojecki, an entrepreneur entered in the Polish Central Registration and Information on Business (CEIDG), address for service (adres do doręczeń): Miłochniewice 17, 96-130 Głuchów, Poland, NIP 8351582374, REGON 368656712 ("TrimCI", acting as processor). It governs the processing of personal data that TrimCI carries out on the Customer's behalf when providing the service described in the Terms of Service — i.e. the personal data contained in Customer Data as described in Annex 2. It does not cover data TrimCI processes as an independent controller (account and organization data), which is described in the Privacy Policy. In case of conflict between this DPA and the Terms of Service or any other agreement, this DPA prevails in matters of personal data protection.
2. Acceptance and duration
This DPA is concluded in electronic form (Art. 28(9) GDPR): it is incorporated by reference into the Terms of Service and accepted by the person who registers the account and creates the organization, who warrants that they are authorized to bind the Customer. TrimCI records the accepted version and the time of acceptance. The DPA remains in force for as long as TrimCI processes personal data on the Customer's behalf, including the wind-down period after termination. This page can be saved or printed for your records, and every previous version is available on request.
3. Definitions
Terms such as "personal data", "processing", "controller", "processor", "data subject" and "personal data breach" have the meanings given in Regulation (EU) 2016/679 (GDPR). This DPA shall be read and interpreted in the light of the GDPR and shall not be interpreted in a way that conflicts with it or limits the rights of data subjects.
4. Instructions and purpose limitation
TrimCI processes personal data only on the Customer's documented instructions, including with regard to transfers to third countries, unless required to do otherwise by Union or Member State law — in which case TrimCI will inform the Customer of that legal requirement before processing, unless the law prohibits it. The complete documented instructions are: this DPA, the Terms of Service, and the Customer's configuration inside the service (which providers are connected, which repositories are tracked, when reports and recommendations are generated). TrimCI processes the data exclusively for the purposes set out in Annex 2 — CI/CD pipeline failure analysis, cost estimation, and optimization recommendations for the Customer — and never for TrimCI's own purposes. TrimCI will immediately inform the Customer if, in its opinion, an instruction infringes the GDPR or other Union or Member State data protection law.
5. Confidentiality
TrimCI grants access to the personal data only to persons who need it to provide the service and who have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
6. Security of processing
TrimCI implements the technical and organisational measures specified in Annex 3, taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of the processing, so as to ensure a level of security appropriate to the risk (Art. 32 GDPR), including protection against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to the data.
7. Sensitive data
The service is not intended for processing special categories of personal data (Art. 9 GDPR) or data relating to criminal convictions (Art. 10 GDPR). Failed-job log excerpts may incidentally contain personal data printed by the Customer's pipelines; this risk is mitigated by collecting at most the last 8,000 characters of failed jobs only, redacting known secret formats, and permanently deleting the excerpts after 30 days. The Customer agrees not to deliberately route special-category data through CI logs.
8. Documentation and audits
TrimCI makes available to the Customer all information necessary to demonstrate compliance with Article 28 GDPR — starting with this DPA, the security page and the sub-processor list — and allows for and contributes to audits, including inspections, conducted by the Customer or an auditor mandated by the Customer. Audits are carried out at reasonable intervals or where there are concrete indications of non-compliance, with reasonable advance notice, during business hours, and without endangering the confidentiality of other customers' data; existing documentation and third-party attestations will be taken into account first. TrimCI maintains a record of processing activities carried out on behalf of the Customer (Art. 30(2) GDPR), available on request.
9. Sub-processors
The Customer grants TrimCI general written authorisation to engage the sub-processors listed in Annex 4, which is kept up to date at the sub-processor page. TrimCI will inform organization owners and admins by email of any intended addition or replacement of a sub-processor at least 30 days before it takes effect, giving the Customer the opportunity to object. If the Customer objects on reasonable data protection grounds and no solution is found in good faith, the Customer may terminate the service before the change takes effect; absence of an objection within the notice period constitutes approval. TrimCI imposes on every sub-processor, by way of a contract, in substance the same data protection obligations as set out in this DPA, and remains fully liable to the Customer for the performance of the sub-processor's obligations.
10. International transfers
All processing performed by TrimCI under this DPA takes place within the European Union; TrimCI does not transfer the personal data outside the European Economic Area. Any future transfer to a third country will take place only on the Customer's documented instructions or where required by Union or Member State law, and only in compliance with Chapter V GDPR.
11. Assistance to the Customer
TrimCI promptly notifies the Customer of any request received directly from a data subject concerning data processed under this DPA, and does not respond to it itself unless authorised by the Customer. Taking into account the nature of the processing, TrimCI assists the Customer, by appropriate technical and organisational measures and insofar as this is possible, in fulfilling the Customer's obligations to respond to data subject requests (Chapter III GDPR), and — taking into account the information available to TrimCI — in ensuring compliance with the Customer's obligations regarding security of processing, breach notification, data protection impact assessments and prior consultation (Articles 32 to 36 GDPR). The Customer remains responsible for informing its own team members and pipeline actors about the processing of their data in connection with the Customer's use of the service.
12. Personal data breach notification
TrimCI notifies the Customer without undue delay after becoming aware of a personal data breach concerning data processed under this DPA. The notification includes, at least: a description of the nature of the breach (including, where possible, the categories and approximate numbers of data subjects and records concerned), the likely consequences, the measures taken or proposed to address the breach, and a contact point — the information the Customer needs for its own notification obligations under Articles 33 and 34 GDPR.
13. Deletion or return of data
Upon termination of the service, TrimCI will, at the Customer's choice, delete or return all personal data processed under this DPA and delete existing copies, unless Union or Member State law requires further storage. Concretely: deleting the organization (which happens when the owner deletes their account and is the organization's only member) permanently deletes its Customer Data; failed-job log excerpts are in every case automatically deleted after 30 days. A request for return of data in a structured format may be sent to office@trimci.com before deletion.
14. Non-compliance and termination
Without prejudice to the GDPR, if TrimCI is in breach of its obligations under this DPA, the Customer may instruct TrimCI to suspend the processing until the breach is remedied, and may terminate the service where the breach is substantial or persistent and not remedied within a reasonable time. TrimCI may terminate the service where the Customer insists on an instruction that TrimCI has flagged as infringing applicable data protection law.
15. Liability
The liability of the parties for damage caused by processing infringing the GDPR is governed by Article 82 GDPR. TrimCI is fully liable to the Customer for the performance of the obligations of any sub-processor it engages. The liability limitations of the Terms of Service apply between the parties to the extent permitted by law; they never limit the rights of data subjects.
16. Changes to this DPA
Material changes to this DPA are announced to organization owners and admins by email at least 30 days before they take effect; the sub-processor procedure of Section 9 applies to sub-processor changes. The version number and effective date at the top of this page identify the current text.
17. Governing law
This DPA is governed by Polish law and, in matters it regulates, by the GDPR directly. Venue follows the Terms of Service.
Annex 1 — Parties
Processor: Bogusław Chojecki, an entrepreneur entered in the Polish Central Registration and Information on Business (CEIDG), address for service (adres do doręczeń): Miłochniewice 17, 96-130 Głuchów, Poland, NIP 8351582374, REGON 368656712, contact office@trimci.com. Controller: the Customer — identified by the organization name, and the name and email address of the accepting account holder, as recorded by the service at acceptance.
Annex 2 — Description of the processing
| Element | Description |
|---|---|
| Subject matter and nature | Automated retrieval, storage and analysis of CI/CD pipeline observability data from providers connected by the Customer (GitHub Actions, GitLab CI). |
| Purpose | Pipeline failure analysis, cost estimation, reporting, and optimization recommendations for the Customer. |
| Duration | For the term of the service contract, plus the deletion wind-down described in Section 13. |
| Categories of data subjects | Members of the Customer's organization; persons who trigger CI pipeline runs in connected repositories (developers, committers, reviewers); persons whose data incidentally appears in failed-job logs. |
| Categories of personal data | Usernames/handles of pipeline actors; run/job timestamps, durations and conclusions attributable to those actors; incidental personal data contained in the last 8,000 characters of failed-job logs. (Account, organization and invitation data is processed by TrimCI as an independent controller — see Section 1 and the Privacy Policy.) |
| Special categories | None intended (see Section 7). |
| Retention | Failed-job log excerpts: 30 days. Pipeline metadata: for the duration of the contract, deleted with the organization. Historical back-fill on first connection: at most 60 days. |
Annex 3 — Technical and organisational measures
- Encryption in transit: all traffic over TLS (browser–service and service–provider APIs).
- Encryption at rest of provider credentials: CI provider tokens are stored encrypted (Fernet, AES-based); authorization headers are redacted from logs.
- Data minimisation by design: a runtime HTTP allowlist rejects any provider API call outside pipeline, job and project-listing endpoints — source code, workflow files and diffs are technically unreachable.
- Log handling: only the last 8,000 characters of failed jobs are collected; known secret formats are redacted before any AI processing; excerpts are automatically deleted after 30 days.
- AI locality: log analysis is performed by a self-hosted language model on TrimCI's own infrastructure; no data is sent to external AI providers.
- Access control: passwords stored as salted hashes; email verification at signup; per-organization tenant isolation validated on every request; management actions gated by role (owner/admin).
- Infrastructure: hosted in the European Union (Hetzner); services isolated in containers; databases not exposed publicly.
- Availability and integrity: infrastructure-level backups; automated cleanup jobs (log purge) run daily; measures are reviewed periodically and after every significant change.
- Organisational: access to production restricted to authorized persons bound by confidentiality; sub-processors bound by data protection contracts.
Annex 4 — Authorised sub-processors
The current, maintained list is published at the sub-processor page. At the date of this version it comprises: Hetzner (infrastructure hosting, European Union) and Brevo (transactional email delivery, European Union). AI analysis involves no sub-processor — it runs on a self-hosted model on TrimCI's own infrastructure.