Data Processing Agreement

Summary

• For group content, the customer is the data controller and JodJam is the processor, acting only on the customer’s documented instructions. Those instructions are this agreement plus the settings the customer chooses in the product (AI on/off, own API key, retention, deletion, and the declared type of each group).
• For account, billing and usage-metadata, JodJam is itself the controller. This dual role is stated openly rather than buried.
• The customer warrants that every connected group is operated for the organisation, that they have told the group’s members about the backup using the notices the product provides, and that they hold a lawful basis under PDPA for every member of every connected group — their own people and any outsiders alike. Personal use, or use unrelated to the organisation, breaches this agreement.
• JodJam does not collect per-member consent on the customer’s behalf and does not condition capture on it. What it provides is the telling: an announcement card posted in the group when it is connected to an account, or when the declared controller changes, a notice to members who join later, and templates the customer can post themselves. Changing a group’s declaration on the settings screen is recorded as evidence and posts nothing into the group.
• Accepting this agreement ratifies the up-to-7-day quarantine window that precedes claiming a group. If a group is never claimed, that data is deleted automatically.
• Security measures: AES-GCM encryption of stored API keys, private object storage behind signed or authenticated URLs, role-based access limited to members of that group via LINE Login, no message content in logs, and permanent deletion of recalled messages including their files.
• Data-subject support: per-member export, per-member erasure, and an option to erase a member’s data when they leave the group.
• Subprocessors: Cloudflare (infrastructure), Google (AI), OpenAI (image generation), SlipOK / EasySlip (slip verification). 15 days’ notice before adding or changing one; the customer may object and, failing a resolution, terminate. LINE is a platform dependency and an independent controller, not a subprocessor.
• Data is stored and processed outside Thailand; the customer’s use of the service is their instruction to transfer it as necessary.
• Audit is report-based, not on-site, which is what a multi-tenant service can honestly offer.
• JodJam may suspend processing for a group or account that breaches the warranties above. Thai law governs. Data-protection contact: pdpa@jodjam.com.