- Deployment
- hosted
- Hq Country
- Singapore
- Hq City
- Singapore
- Ownership
- private
- Founded
- 2019
- Training Default
- never
- Residency Options
- Singapore
- Gov Access Exposure
- prc-nil
- Eu Ai Act Role
- gpai
- DPA available
- yes
- Zero Retention Available
- Yes
- Retention Default
- "The Company do not store any of the content the Customer or its End Users provide or generate while using our Services. This includes any texts, or other data you input. This information is processed in real-time to provide the Customer and End Users with the API Service and is not saved on our servers." — DPA for API Services, clause 4(b).
- Retention Exceptions
- The consumer-facing side of the same policy is materially different: it gives a legitimate-interests basis for processing personal data "including in developing, improving, or promoting our Services, such as when we train and improve our models". The zero-retention commitment is specific to the API DPA.
- Subprocessor Count
- 0
- Transfer Mechanism
- none-stated
- Eu Procurement Ready
- fail
- Eu Procurement Reason
- The API DPA is genuinely good — controller/processor roles set out properly, Singapore processing, and an explicit statement that no input content is stored. What it does not do is name a single subprocessor, name any Article 46 transfer instrument (only "legally recognized transfer mechanisms"), or mention China anywhere. The controller of record is JINGSHENG HENGXING TECHNOLOGY PTE. LTD in Singapore; the models are GLM, and the Z.ai Group is the Zhipu AI group, which puts the PRC National Intelligence Law over the corporate parent. Singapore has no EU adequacy decision.
- Training Claim Basis
- stated
- Training Confidence
- medium
- Residency Claim Basis
- stated
- Residency Confidence
- high
- Retention Claim Basis
- stated
- Retention Confidence
- high
- Subprocessors Claim Basis
- inferred
- Subprocessors Confidence
- low
- Residency Class
- non-eu-only
- Portability / Exit Path
- serves-open-models
- Subprocessor Jurisdiction
- undisclosed
- Underlying model providers
- Z.ai / Zhipu AI (GLM)
