DPA, sub-processor matrix, liability allocation, sample DPO export.
Trust Center
What procurement, security and legal can assess today.
Updated 8 October 2026
The data processing agreement, the full sub-processor list with the country and transfer basis for each, where data is hosted, how long it is kept, what we hold no certification for, and exactly what the Audact guarantee covers. No form, no NDA and no call in between.
What you have to be able to show
- A written contract with your processor covering scope, duration, instructions, confidentiality, security and sub-processing.
- Regulation (EU) 2016/679 (GDPR), Art. 28(3)
- A record of processing activities, per purpose, with retention periods and categories of recipient.
- Regulation (EU) 2016/679, Art. 30
- Technical and organisational measures appropriate to the risk, including encryption where appropriate.
- Regulation (EU) 2016/679, Art. 32
- Notification of a personal data breach to the supervisory authority within 72 hours where feasible.
- Regulation (EU) 2016/679, Art. 33(1)
- That a person interacting with an AI system is told so, unless it is obvious from the circumstances.
- Regulation (EU) 2024/1689 (AI Act), Art. 50(1), has applied since 2 August 2026
- For a white-label deployment: the party that puts its own name on a product is treated as its manufacturer.
- Directive (EU) 2024/2853 (product liability), Art. 8, applies from 9 December 2026; a directive, so transposition runs per member state
What Audact provides for it
- Article 28 data processing agreement, with the sub-processor chain; crypto-shredding for erasure: coming soon.
- Counsel review
- Sub-processor list with country, function, data category and transfer basis; 30 days' notice before a new one is added.
- Primary application hosting in Frankfurt (AWS eu-central-1), TLS 1.3 in transit and AES-256 at rest.
- A compliance receipt per governed interaction, three fields of which anyone can recompute without a key.
- A DPIA template your own data protection officer can adapt.
- Not available
- ISO 27001, ISO 42001, SOC 2 Type II.
- Not certified — see the table below
At a glance
Each line with the kind of status that fits it.
Every line below is either a document on this page, a link, or a statement we will repeat in writing on request. The status word follows the kind of thing it describes, because one word cannot carry six kinds of fact: a company is verified in a public registry, a technical control is implemented, a contract is in draft, under counsel review or contractual, a template is available or it is not, a product is in controlled testing, and a certification is held or it is not.
Dylan, quality assurance, tests the compliance checks against live calls and records, per check, what it actually does. The measurements behind the product status on this site are his.
- Item
- IP-holding entity
- Position
- Audact AI Ltd, Companies House 17059133, London
- Status
- Verified in registry
- Item
- Operating company
- Position
- AUDACT AI LIMITED, Ireland, CRO 822514
- Status
- Verified in registry
- Item
- Hosting region
- Position
- AWS Frankfurt (eu-central-1) — primary application hosting
- Status
- Implemented
- Item
- Data roles
- Position
- Audact is processor or sub-processor; the customer is controller, or itself processor towards its own end-client. Set per deployment in the DPA (GDPR Art. 28)
- Status
- Contractual
- Item
- Sub-processors
- Position
- Full list below · 30 days' notice before a change
- Status
- Published below
- Item
- Retention
- Position
- Call audio not retained by default; up to 90 days if recording is on · evidence chain per the agreement
- Status
- Implemented
- Item
- Encryption
- Position
- TLS 1.3 in transit · AES-256 at rest
- Status
- Implemented
- Item
- Crypto-shredding
- Position
- On erasure
- Status
- coming soon
- Item
- DPA / AVV
- Position
- Article 28-aligned; final wording pending counsel sign-off
- Status
- Counsel review
- Item
- Sample compliance receipt
- Position
- /sample-receipt.json, /sample-receipt.pdf and /sample-receipt-readme.txt (the canonical form, which block feeds which value, and four test vectors) · open, no account
- Status
- Available
- Item
- Security contact
- Position
- security@audact.ai · coordinated disclosure policy published
- Status
- Published
- Item
- Launch scope
- Position
- Voice in controlled testing · Article 50 policy: Germany active, Netherlands in progress
- Status
- In controlled testing
Sub-processors
Every party that touches the data, with the country it sits in.
We notify customers 30 days before adding a new sub-processor. Several of the parties below are US-incorporated; those transfers run under standard contractual clauses.
- Provider
- AWS (Frankfurt)
- Country / basis
- EU (Frankfurt) for hosting; CloudFront and Route 53 are global services with points of presence outside the EU.
- Function
- Infrastructure hosting, CDN (CloudFront), DNS (Route 53), WebRTC transport (self-hosted LiveKit)
- Data category
- All platform data
- Provider
- Telnyx
- Country / basis
- EU points of presence · SCCs
- Function
- SIP telephony
- Data category
- Call audio in transit, telephony metadata
- Provider
- Deepgram Nova-3
- Country / basis
- US (EU endpoint) · SCCs
- Function
- Speech to text
- Data category
- Audio in transit (no retention configured)
- Provider
- Mistral (Voxtral)
- Country / basis
- EU
- Function
- Text to speech
- Data category
- Model-generated text
- Provider
- Mistral / OpenAI
- Country / basis
- EU (Mistral) / US EU-endpoint (OpenAI) · SCCs
- Function
- Model inference (mini models), selected per agent configuration
- Data category
- Conversational text (no retention configured)
- Provider
- freeTSA.org
- Country / basis
- External public service
- Function
- RFC 3161 timestamping
- Data category
- Digest only — no readable content
- Provider
- Google Workspace
- Country / basis
- US / EU · SCCs
- Function
- Email, documents
- Data category
- Business communications
- Provider
- Slack
- Country / basis
- US · SCCs
- Function
- Internal communications, including notifications of website enquiries
- Data category
- Internal messages; enterprise enquiry form fields (name, organisation, email, sector, volume, message) and IP address
- Provider
- Notion
- Country / basis
- US · SCCs
- Function
- Wiki and documentation
- Data category
- Internal operational data
- Provider
- Linear
- Country / basis
- US · SCCs
- Function
- Project management
- Data category
- Internal project data
- Provider
- 1Password
- Country / basis
- Canada / EU
- Function
- Credential management
- Data category
- Encrypted credentials
- Provider
- Stripe (billing in development; no date set)
- Country / basis
- US / IE · SCCs
- Function
- Payment processing
- Data category
- Billing data
Sub-processor list last updated: 5 October 2026
Certification status
What we hold, and what we do not.
Audact holds no security or AI management certification.
- Standard
- GDPR
- Status
- Legal obligation, not a certificate
- Note
- Article 28 DPA under counsel review; the Article 30 summary is further down this page.
- Standard
- EU AI Act, Article 50
- Status
- Supported since 2 August 2026
- Note
- Article 50 is a transparency duty. It carries no certificate and no harmonised standard, so no vendor can be certified for it.
- Standard
- ISO/IEC 27001
- Status
- Not certified
- Note
- No audit is under way and none is booked. Controls built against the Annex A set; we walk them line by line on request.
- Standard
- ISO/IEC 42001
- Status
- Not certified
- Note
- No track started. The harmonised European standards under the AI Act are not final, so an assessment today would be measured against a moving target.
- Standard
- SOC 2 Type II
- Status
- Planned, no auditor engaged
- Note
- Sequenced after the first paying deployments so the scope reflects real production controls.
- Standard
- EU AI Pact
- Status
- Signatory
- Note
- A voluntary public commitment listed on the Commission register. Not a certification and not an approval.
EU AI Pact
Signatory to the voluntary Pillar II commitments.
Audact AI Ltd is a signatory to the European Commission's AI Pact and submitted its Pillar II voluntary commitments on 10 June 2026. The company appears on the Commission's public signatory register, which means a third party can check this without asking us. That is why it is here.
The Commission states that the pledges are not legally binding and impose no legal obligations on participants. Signing is therefore not a certification, not an audit and not a regulatory approval; it does not make a system conform to the AI Act and creates no legal presumption that it does.
Records of processing
Article 30 summary.
A public summary of the record of processing activities. A per-customer record does not exist yet; the first one is drawn up with the first paying deployment.
- Processing categories: voice AI agent calls inbound and outbound, evidence chain attestation, brand governance validation, billing.
- Data subjects: the end clients and callers of Audact's agency customers.
- Retention: call audio is not retained by default; where the customer switches recording on it is kept for up to 90 days. Evidence-chain records are kept for the term of the agreement and thereafter only as long as the customer’s applicable rule requires.
- Lawful basis: performance of the contract (Art. 6(1)(b)) for the Audact-to-agency relationship. The agency is responsible for the lawful basis towards the end caller.
Security summary
The controls, described rather than certified.
- Control
- Encryption
- What is in place
- TLS 1.3 in transit and AES-256 at rest; crypto-shredding for retention-expired personal data is coming soon.
- Control
- Access control
- What is in place
- Role-based access, multi-factor authentication mandatory for all administrative access, admin audit log retained 2 years.
- Control
- Evidence integrity
- What is in place
- Append-only, hash-chained records: a later change or reordering is detectable by recomputation against a retained commitment.
- Control
- Penetration testing
- What is in place
- Not yet carried out. A first external test is scheduled before the first paying deployment; the date appears here once it is booked.
- Control
- Incident response
- What is in place
- Audact notifies the customer without undue delay after becoming aware of a personal-data breach. The controller carries the Article 33(1) deadline to the supervisory authority.
- Control
- Vulnerability disclosure
- What is in place
- Published coordinated disclosure policy with a safe-harbour commitment and a 48-hour acknowledgement.
Marketing claim matrix
What an agency, and Audact, may say in public.
- Claim
- Article 50 disclosure-ready architecture
- Allowed
- Yes
- Why
- The disclosure is delivered in the call and recorded per interaction.
- Claim
- Cryptographic evidence chain
- Allowed
- Yes
- Why
- SHA-256 hashing, Merkle aggregation and a chained receipt per interaction.
- Claim
- Patent-pending
- Allowed
- Yes
- Why
- Accurate: applications are filed at the UK IPO and none is granted.
- Claim
- Patent-protected
- Allowed
- No
- Why
- Misleading before grant. Say patent-pending.
- Claim
- EU-sovereign
- Allowed
- No
- Why
- AWS Frankfurt is physically in the EU and legally US-owned. Say EU-hosted.
- Claim
- Evidence that will hold up in court
- Allowed
- No
- Why
- No court has ruled on it. Say tamper-evident records, or audit-ready receipts.
- Claim
- Receipts a third party can check entirely on their own
- Allowed
- No
- Why
- Three values can be recomputed without a key today; a fourth, inclusion in the Merkle root, is checked against the published root with the inclusion proof from the call's Article 50 report. The authentication code cannot be recomputed at all without the key, because it is keyed and we hold that key. Name the three, and say where the fourth stands.
- Claim
- Naming a competitor as operating unlawfully
- Allowed
- No
- Why
- Defamatory, and in Germany actionable under the UWG. State a specific sourced fact with its date instead.
- Claim
- Guaranteed compliance
- Allowed
- No
- Why
- The guarantee covers misses by the governed engine only. See its scope below.
Intellectual property and entities
Who holds what.
- Patent-pending governance stack, filed at the UK Intellectual Property Office by Audact AI Ltd. All filings are filed applications; none is granted, none has been searched or examined, and nothing here should be read as a blocking claim against any company.
- Audact AI Ltd — UK Companies House number 17059133 — is the IP-holding entity.
- AUDACT AI LIMITED — Ireland, CRO 822514 — is the operating company. Which Audact company is party to your contract is set in the order form you sign; the DPA, section 1, states the position.
- Which of the two is party to a given contract is named on the signed order form. An agreement signed with the UK company is assigned to the Irish company by written notice, effective on the date of that notice. This page does not assert that every existing agreement has already been assigned. Ask legal@audact.ai for the position on your own contract before you sign.
- Detailed IP documentation is available to customers and counsel on request.
Where the stack is going
EU-native sourcing, layer by layer.
Some current sub-processors are US-incorporated but physically EU-hosted. The table says where each layer stands and what is being evaluated. We publish no target date until a move is contracted.
- Layer
- Compute
- Today
- AWS Frankfurt (physically EU, legally US)
- Under evaluation
- A German provider, legally and physically EU
- Layer
- Telephony (SIP)
- Today
- Telnyx EU points of presence
- Under evaluation
- Stable, no change planned
- Layer
- Speech to text
- Today
- Deepgram (US, EU endpoint)
- Under evaluation
- An EU-domiciled provider
- Layer
- Text to speech
- Today
- Mistral Voxtral (EU)
- Under evaluation
- EU-domiciled provider — in place today
- Layer
- Model inference
- Today
- Mistral (EU) / OpenAI (US, EU endpoint), mini models
- Under evaluation
- Mistral is EU-domiciled; OpenAI runs via its EU endpoint
The Audact guarantee
A narrow guarantee, and its edges.
If the governed engine should have stopped an utterance under the active rules and did not, you get the evidence file to answer with, and any financial compensation your signed order form provides. It is deliberately narrow, and the second list is the part worth reading twice.
- Covered: misses by the Audact governance engine — cases where the engine should have blocked an utterance under the active rules and did not.
- Not covered: prompt engineering by the customer that works around the intent of a policy.
- Not covered: misuse by the end client, including switching compliance rules off.
- Not covered: obligations outside the jurisdictions that are configured.
- Not covered: deployments that required a fundamental rights impact assessment where the customer did not complete one.
- Not covered: regulatory changes after deployment. We update the rule set; the obligation to migrate stays with the customer.
Status and contact
How to reach a person, and what is not running yet.
A public status page with uptime metrics and incident history is in development. Until it exists, service status is communicated to customers directly.
The production export of a set of receipts worked when it was retested on 26 August 2026 after the deploy: five calls, thirty validated turns, thirty receipts, across two agents and two configurations, measured on browser calls rather than over a telephone line.
- security@audact.ai: security disclosures and the coordinated disclosure policy.
- privacy@audact.ai: data subject requests and GDPR matters.
- legal@audact.ai: contractual questions, and requests for the DPA as a PDF.
- regulators@audact.ai: supervisory authorities, data protection officers and counsel.
Questions
- Do you have ISO 27001 or SOC 2 Type II?
- No. Audact holds no ISO 27001, no ISO 42001 and no SOC 2 Type II report, and no audit is currently engaged. The controls are documented and we will walk a security team through them line by line, but no external auditor has assessed them.
- Where is the data?
- Primary application hosting is Frankfurt, on AWS eu-central-1. Several sub-processors are US-incorporated and those transfers run under standard contractual clauses; the full list with the basis for each is on this page.
- Can I see the DPA before I sign anything?
- Yes. The Article 28 terms are published at /legal/dpa. The final PDF, with the counsel-reviewed wording, is provided during onboarding; write to legal@audact.ai if you need it earlier for a procurement review.
- Can a third party check a receipt without going through Audact?
- Three of its elements, today: the input hash, the output hash and the link to the receipt before it. A fourth, inclusion in the Merkle root, is checked against the published root with the inclusion proof from the call's Article 50 report. The roots are published at api.audact.ai/v1/metachain. The fifth, the authentication code, is a keyed MAC under a symmetric key held by Audact — whoever can check it can also produce it.
- Is the timestamp a qualified eIDAS timestamp?
- No. It is an RFC 3161 timestamp from freeTSA.org, a free public service. It fixes an ordering against our own chain; freeTSA.org is not an eIDAS-qualified trust service, so this is not a qualified timestamp and we do not present it as one.
- How much notice do we get before a sub-processor changes?
- Thirty days before a new sub-processor is added, in writing, with the country and the transfer basis. You can object within that window under the DPA.
The technical side of the same question
The security page carries the sub-processor matrix as a downloadable file, the liability allocation between Audact and an agency under the AI Act, the EU Data Act switching terms, and a sample DPO export bundle.
Related
Security architecture Report a vulnerability Coordinated disclosure policy, safe harbour, acknowledgement times.
Regulator proof room For supervisory authorities and DPOs: how a receipt is checked.
Data Processing Agreement The Article 28 terms, published as a draft under counsel review.
See a receipt Field by field, and exactly what a receipt is a record of.
EU AI Act, Article 50 What the law requires, with the article numbers.
