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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.
Published below
Primary application hosting in Frankfurt (AWS eu-central-1), TLS 1.3 in transit and AES-256 at rest.
Implemented
A compliance receipt per governed interaction, three fields of which anyone can recompute without a key.
Working today
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.

Security and compliance architecture

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