Version 1.0 · 12 November 2026
Agree these terms before business processing. This is Roger’s standard data-processing addendum for written agreement with a business customer. Publication alone does not execute an agreement, approve a particular use or confirm that a customer’s provider and international-transfer checks are complete.
1. Parties, scope and agreement
Roger Assistant, Inc. (Delaware file number 10833575) is the processor for personal data it processes solely on the documented instructions of the business customer identified in the written service agreement or confirmation. That customer is the controller, or an authorised processor instructing Roger on behalf of its controller. “Applicable data protection law” means the UK GDPR and Data Protection Act 2018, as amended, and EU GDPR where applicable.
To put this addendum in place, contact privacy@rogerassistant.com. The written confirmation must identify the customer’s legal name and contact, Roger account, authorised representative, agreed features, purposes and duration, data and people covered, authorised providers and processing locations, and applicable transfer safeguards. It must reference this version and record both parties’ agreement. Retain that confirmation with these terms. An existing contract is not transferred to a new company merely by publishing this page.
This addendum takes priority over conflicting service terms for the processing it covers. Roger remains a separate controller for purposes it determines, such as account administration, security and legal obligations, as described in the privacy notice.
2. Processing schedule
- Subject and purpose: providing the agreed Roger assistant features for business administration, meeting or job notes, transcription, summaries, drafts and approved actions.
- Operations: collecting and uploading supplied content; storing, transcribing, distinguishing speakers within a recording, retrieving, analysing and summarising it; preparing documents and actions; transmitting approved content to selected recipients or connected tools; returning or deleting data.
- Duration: the agreed service period and the time needed to return or delete data under section 8. Current cloud recordings, transcripts and assistant records are retained until deletion is requested; finishing a report does not erase its source.
- Personal data: names, contact details, voices, meeting and call recordings, transcripts, messages, attachments, job and customer details, account identifiers and authorised connected-account content. Optional photo and location sharing is included only if specifically enabled and agreed.
- People: the customer and its personnel, clients, prospects, suppliers, contractors, meeting participants, callers and other people whose details the customer lawfully supplies.
- Sensitive information: do not supply special-category data, criminal-offence data or information subject to professional secrecy unless the purpose, legal conditions and safeguards have been specifically agreed in writing first. Voice recordings can contain sensitive information even where that was not intended.
3. Instructions and customer responsibilities
Roger shall process customer personal data only on documented instructions, including for international transfers, unless applicable law requires otherwise. In that case Roger shall notify the customer of the legal requirement before processing unless the law prohibits notification. Roger shall immediately inform the customer if, in its opinion, an instruction infringes applicable data protection law and may pause the affected processing while it is resolved.
Instructions include the agreed schedule, configured features and authorised requests retained in the account or correspondence. The customer determines the lawful purposes and legal basis, provides appropriate notices, obtains required recording permissions, and ensures it may disclose the data and authorise connected-account access. The customer reviews outputs, recipients and proposed actions. Roger shall not sell customer content or use audio, transcripts, chats, attachments or connected-account data to train or fine-tune general-purpose AI models, and shall require the same exclusion from its AI processing providers. This is not a promise of zero provider retention.
4. Confidentiality and security
Roger shall ensure that people authorised to process customer data are bound by confidentiality duties and receive access only for their authorised work. Roger shall implement and maintain technical and organisational measures appropriate to the risk under Article 32, including access restrictions and account separation, protection of credentials, encryption in transit and at rest where data is stored, incident handling, recovery arrangements, and regular assessment of the effectiveness of security measures.
The operational security scope and any additional measures shall be documented in the customer’s confirmation. Authorised Roger operators can access content for support and operation; this is not a service where only the customer holds decryption keys. The public recording, access and deletion explanations describe material limitations. Do not infer a certification, penetration-test result, dedicated tenancy, UK-only hosting or end-to-end encryption from these terms.
5. Providers and authorisation
Roger shall use a sub-processor only with the customer’s prior specific or general written authorisation. Roger shall impose written obligations offering equivalent protection for the relevant processing and remain responsible to the customer for the sub-processor’s performance of those obligations. Under general authorisation Roger shall notify the customer before adding or replacing a sub-processor, allowing a reasonable opportunity to object on data-protection grounds before the affected processing begins. The parties shall resolve the objection through an alternative or by stopping the affected feature.
The following is the current service map, not evidence that every provider has received a particular customer’s data. The customer’s agreed schedule must identify the applicable provider legal entities, locations and contractual arrangements before the relevant feature is used.
- Supabase: recording database and private storage; optional shared photos and location data. The recording project is hosted in Ireland.
- Render: recording and background processing. ElevenLabs: current speech transcription. pyannote: anonymous speaker separation within a recording.
- Vercel: assistant hosting, runtime and AI Gateway. Neon: assistant conversation and action records. OpenAI: assistant text reasoning through AI Gateway; historical recording or calling paths may also have used direct OpenAI processing.
- Kernel and Meta models through AI Gateway: hosted browser tasks when requested, with relevant website and task content.
- Composio: authorised Google connection credentials and API requests. Existing Vercel Connect grants may remain relevant to older connections.
- Revox: requested outbound calls, including the recipient number, approved instructions and call results.
- Meta WhatsApp: messages and attachments exchanged with Roger. Google and customer-selected software: content accessed or written through authorised connections. Their roles may include independent-controller processing under their own terms; they are not all automatically Roger sub-processors.
6. International transfers
Processing is not limited to Ireland, the UK or Europe. Roger shall make restricted transfers only in accordance with applicable law, using an applicable adequacy decision or appropriate safeguards, including the relevant standard contractual clauses and UK Addendum or International Data Transfer Agreement where required, with the required transfer assessment and supplementary measures. The customer’s written schedule must record the destinations and actual safeguard for each applicable transfer. This page does not itself execute transfer clauses or establish that every provider or recipient is covered by adequacy. If the required safeguard is unavailable, the affected processing shall not begin or shall be suspended.
7. Rights requests, incidents and assurance
Taking account of the nature of processing and information available, Roger shall assist the customer with individuals’ rights requests through appropriate technical and organisational measures, and with security, breach notifications, data protection impact assessments and prior consultation obligations under Articles 32–36. Roger shall pass on requests concerning customer-controlled data without undue delay and shall not independently answer them except on instructions or as legally required.
Roger shall notify the customer without undue delay after becoming aware of a personal data breach affecting the covered data. The notification shall provide available information about the nature of the breach, affected data and people, likely consequences, measures taken or proposed, and a contact for follow-up. Information may be supplied in stages without undue further delay. The customer remains responsible for deciding its own regulatory and individual notifications.
Roger shall provide information needed to demonstrate compliance with Article 28 and allow and contribute to audits and inspections by the customer or its mandated auditor. Reasonable confidentiality, notice and security arrangements may protect other customers without preventing necessary verification or regulator access.
8. Return, deletion and pending cleanup
At the end of the relevant service, Roger shall, at the customer’s choice, return or securely delete the personal data and delete existing copies unless applicable law requires retention. Selected recording deletion can also be requested during service. Roger shall explain any necessary retention, restrict use of retained data to that purpose and delete it when the requirement ends.
Deletion is tracked in separate stages: cloud recordings and transcripts, processing files and queues, assistant history and memory where in scope, external providers, and recordings on the phone. Recording-only deletion does not include excerpts already retained in earlier chats or memories. Account-wide deletion includes those Roger records. Already delivered WhatsApp messages, emails, exported documents and recipients’ copies cannot be recalled through Roger deletion. A phone or separate wearable may need its own local erasure.
“Other service providers — pending” means external cleanup or retention confirmation is not yet fully verified. It is a combined status, not a provider-by-provider inventory, and does not prove that every provider still holds a copy. Speech and speaker-processing services, AI services, hosting/runtime histories and backup retention can need separate checks according to the features actually used. Roger shall provide a case-specific explanation of identified providers and any gaps; it shall not mark this stage complete merely because its own cloud copy was removed.
Where backups cannot be erased immediately, the affected data shall be put beyond ordinary use, protected until deletion on the applicable cycle, and deletion instructions reapplied before any restoration. Roger shall record and communicate outstanding provider and backup retention where known rather than promise an unverified expiry date. Minimal restricted receipts and identifiers may be retained where needed to evidence the request and prevent deleted data returning.
9. Using a separate Gmail account
A dedicated Gmail account limits the mailbox made available through that connection to the information in that account. It does not keep meeting recordings, transcripts, WhatsApp messages or content deliberately supplied to Roger on the phone alone, or remove the need for a lawful basis, participant notices and appropriate processing terms. Check permissions before connecting; Google may show Composio, and the permissions can be broader than Roger’s currently offered tasks. Disconnecting stops future access through that grant but does not erase content already stored or sent.
10. Contact and version record
For this addendum, the customer processing schedule, provider details, access or deletion requests, contact privacy@rogerassistant.com. Service and order enquiries go to support@rogerassistant.com. Material changes require the parties’ written agreement for an existing processing arrangement; an updated website alone does not replace an agreed version. Confidential customer schedules and deletion records are not published here.