MALI Data Processing Addendum (DPA)

Last Updated: October 2026

1. Roles

• You: Data Controller for your organization’s data.
• MALI: Data Processor providing analytics and agent services.

2. Processing Instructions

MALI processes data only:

• As necessary to provide the platform.
• According to documented instructions from you.
• As required by law.

3. Sub‑Processors

MALI uses these sub‑processors:

• DeepSeek, and Zhipu AI as a backup, to answer AI requests.
• Stripe, for payments and subscriptions.
• IONOS, for hosting and email.

4. Security Measures

MALI implements technical and organizational measures described in the Security Overview.

5. Data Subject Rights

MALI assists you, where feasible, in responding to data subject requests (access, correction, deletion) under applicable law.

6. International Transfers

AI requests are sent to DeepSeek or Zhipu AI, which process them in China. A request can include symbols, holdings and portfolio figures, and the user’s onboarding profile answers. Stripe and IONOS may process data in other countries.

7. Termination

Upon termination, MALI will delete or return personal data, subject to legal retention requirements.