Widrow, a product of A3REV Software · version 1.1 · 7 October 2026 (version 1.0: 22 September 2026)
This agreement is between the business that holds a Widrow tenancy (the Customer) and A3REV Software, ABN 32 556 307 251, Golden Beach, Queensland, Australia (A3REV). It sets out how A3REV handles personal data on the Customer’s behalf when the Customer uses Widrow, which runs on the Digital Employee Framework. It forms part of the Terms of Service and applies from the day the Customer’s tenancy is created. Where this agreement and the Terms of Service disagree about personal data, this agreement wins.
It is written to meet Article 28 of the EU General Data Protection Regulation and its UK equivalent, and the Australian Privacy Act 1988 and the Australian Privacy Principles. Plain words are used throughout; the annex carries the specifics.
1. Roles
The Customer decides why and how personal data is processed, and is the controller. A3REV processes it on the Customer’s behalf, and is the processor. The people whose data is processed are the Customer’s staff, its website’s visitors, its prospects and its contacts, as set out in Annex A.
2. What A3REV does with personal data
A3REV processes personal data only to provide Widrow to the Customer, only on the Customer’s documented instructions, and never for its own purposes. The Customer’s instructions are: this agreement, the Terms of Service, and the settings the Customer chooses in its Tenant Portal and its Digital Employees. If A3REV believes an instruction breaks the law, it tells the Customer before acting on it.
Nothing the Customer gives Widrow is used to train any AI model: not A3REV’s, and not any provider’s.
3. Confidentiality
Every person A3REV allows to process the Customer’s data is bound to confidentiality and is given access only to what their work requires. Access is by role, and every tenancy is isolated from every other.
4. Security
A3REV keeps the measures listed in Annex B in place for the life of the tenancy, and improves them as the risks change. In brief: encryption in transit and at rest, secrets held in a key vault, role-based access with strict isolation between tenancies, automated backups with point-in-time recovery, and a trace on every request so that any action can be reconstructed.
5. Sub-processors
A3REV uses the sub-processors listed in Annex C, and only those. Each is bound by written terms at least as protective as this agreement. A3REV publishes the current list on its website and gives the Customer thirty days’ notice by email before adding or replacing one. If the Customer objects on reasonable grounds within those thirty days and the objection cannot be resolved, the Customer may end the tenancy without penalty under clause 10.
The AI providers the Customer chooses are not A3REV’s sub-processors. The Customer holds those accounts directly, under the provider’s own terms; A3REV sends data to them only because the Customer configured Widrow to.
6. Where data is processed
Personal data is stored and processed in Australia, in the Microsoft Azure Australia East region (Sydney). It leaves Australia only when a provider the Customer chose processes it, in that provider’s own regions, under the Customer’s own agreement with that provider.
For a Customer established in the EU, the EEA or the UK, the parties will also execute the standard contractual clauses for international transfers (module two, controller to processor), which A3REV supplies on request. Those clauses then govern the transfer of that Customer’s data to Australia.
7. Helping the Customer meet its own obligations
A3REV helps the Customer answer requests from the people whose data it holds. Widrow provides the tools directly: every person can see and delete what an assistant remembers about them, and a tenant administrator can export everything held for a person as a file, or erase it, in one click, from Tenant Portal → Settings → Privacy Requests. Where a request needs more than the tools provide, A3REV assists within ten business days of being asked.
A3REV also helps the Customer with security assessments, impact assessments and consultations with a regulator, to the extent the information sits with A3REV.
8. If there is a breach
If A3REV becomes aware of a personal data breach affecting the Customer’s data, it tells the Customer without undue delay and in any case within forty-eight hours of becoming aware, by email to the tenant administrators. The notice says what happened, what data and roughly how many people are affected, what A3REV has done and is doing, and a contact. A3REV keeps the Customer informed as it learns more, and does not tell a regulator or the affected people on the Customer’s behalf unless the Customer asks it to or the law requires it.
9. Audit
Once in any twelve months, on thirty days’ written notice, the Customer or an auditor it appoints may verify that A3REV keeps this agreement, during business hours and without disrupting A3REV’s operations or other customers’ tenancies. A3REV may meet the request with a written report and answers to written questions, and provides an on-site or remote inspection only where the report does not settle a reasonable concern. The Customer bears its own costs; each party keeps what it learns confidential.
10. When the tenancy ends
Ending the tenancy starts a thirty-day countdown, with emailed reminders, during which the Customer may reactivate. When the thirty days end, A3REV permanently deletes everything of the Customer’s on the platform: both search indexes, every file in the tenancy’s storage and every database record keyed to the tenancy. Only invoices and the audit trail remain, for the period tax law requires, and are then deleted. Before the countdown ends, the Customer’s administrators may export what the platform holds for any person using the tools in clause 7.
The Customer’s own sources are never A3REV’s to delete: Company Knowledge is a one-way synced copy of the Customer’s website, document stores and uploads, and the originals stay untouched throughout.
11. Liability and law
Liability under this agreement is subject to the limits and exclusions in the Terms of Service and adds nothing to them. This agreement is governed by the same law and courts as the Terms of Service.
12. Changes
A3REV may update this agreement to reflect changes in the law or in Widrow. A change that reduces the Customer’s protection takes effect thirty days after A3REV emails the tenant administrators; any other change takes effect when it is published, with its date. The current version is always at widrow.ai.
Annex A — The processing
| Subject matter | Providing Widrow: a company knowledge base and a team of governed Digital Employees serving the Customer’s website visitors, staff and administrators. |
| Duration | The life of the tenancy, plus the thirty-day countdown and the deletion in clause 10. |
| Nature and purpose | Storing and indexing the Customer’s connected content; running conversations between people and the Customer’s Digital Employees; carrying out the tool actions the Customer has enabled (email drafts, CRM records, calendar entries and the like) on the Customer’s own connected accounts; remembering, per person, what an assistant has learned; producing documents and files the Customer asks for; notifying the Customer’s administrators; billing the tenancy. |
| People | The Customer’s staff and administrators; visitors to the Customer’s website; the Customer’s prospects, customers and contacts as they appear in conversations, uploads and the Customer’s connected sources. |
| Kinds of data | Names, email addresses, phone numbers and roles; account and sign-in data; the content of conversations and uploaded files; what an assistant remembers about a person; the Customer’s own business content; usage and technical data (IP address, browser, pages visited, timestamps); billing records. No special categories are sought; if the Customer’s content contains any, they are processed under this agreement like everything else. |
Annex B — Security measures
- Encryption in transit (TLS 1.2 or later) and at rest (AES-256).
- Passwords stored only as Argon2id hashes; short-lived signed sign-in tokens.
- Role-based access with strict isolation between tenancies; every person in the Customer’s business sees only what their role allows, and no tenant or partner administrator can browse another person’s assistant memory; the only way its content leaves is the one-person export an administrator runs from Privacy Requests on that person’s request, and every export is written to the audit log.
- Secrets held in Azure Key Vault; service-to-service calls signed.
- Automated database backups with point-in-time recovery.
- A correlation identifier on every request and an audit trail of actions in the tenancy.
- Company knowledge vaulted to the tenancy and used only to ground the Customer’s own Digital Employees.
- The website connector (the Digital Employees plugin) runs on the Customer’s own server and is open source, so the Customer can read exactly what it does.
Annex C — Sub-processors
| Sub-processor | What it does | Where |
|---|---|---|
| Microsoft (Azure) | Hosts and processes the platform: compute, database, storage, search, secrets, monitoring. | Australia East (Sydney). |
| Microsoft 365 | Sends the platform’s own notification emails to the Customer’s administrators. | Microsoft’s regions. |
| Stripe, PayPal | Payment processing for the tenancy’s invoices. A3REV never holds card numbers. | The provider’s regions. |
| Composio | When a person connects their own apps (CRM, mail, calendar), holds the connection that person authorised, in that person’s name. | The provider’s regions. |
Not sub-processors, because the Customer contracts them directly and holds the account: the AI providers the Customer chooses for the model, web research, images and voice.
Annex D — Contacts
Data protection matters, data requests and breach notices: hello@widrow.ai, A3REV Software, Golden Beach, Queensland, Australia.