JarveySign inWhat this is
This Data Processing Agreement ("DPA") forms part of the Terms of Service between you ("Controller") and Comind AI, company registration number 1223189, registered at Office 105, Al Ghanin 3 Building, Al Muraqabat, Dubai, UAE ("Processor", "we", "us"). It is the agreement Article 28 of the GDPR requires between a controller and its processor. It applies whenever we process personal data on your behalf, and it takes effect the moment you start using Jarvey. Nothing needs signing.
Words defined in the GDPR (personal data, processing, controller, processor, sub-processor, data subject, supervisory authority) carry their GDPR meaning here.
Where this DPA and the Terms disagree about processing, this DPA wins.
Who is what
You are the controller of the personal data in your workspace: what your colleagues and your guests say in a call, the transcripts, the recaps, the memory and the names attached to them. You decide who is invited, what Jarvey is told to do, and how long any of it lives.
We are the processor of that data. We are the controller only of your account and of how we run the service (sign-in, billing, security logs and product analytics), and our Privacy Policy covers that part.
What we process, and why
| Subject matter | Running Jarvey: hearing a meeting, answering in it, writing it down |
| Duration | For as long as your workspace exists, and no longer |
| Nature and purpose | Transcription, live answering, recap and memory writing, writing to a board you connect |
| Types of personal data | Names, email addresses, and whatever people choose to say out loud in a meeting |
| Categories of data subject | Your members, your guests, and anyone spoken about in a call |
We do not ask for special category data and Jarvey has no feature that needs it. If your meetings contain it, that is your decision and your lawful basis.
Our obligations
- Instructions. We process personal data only on your documented instructions. Using the product is the instruction. We will tell you if an instruction appears to breach the GDPR, and we will not follow one that clearly does.
- Confidentiality. Everyone with access is bound to confidentiality.
- Security. We keep the measures in "Security measures" below, and we do not weaken them during the term.
- Sub-processors. As set out in the next section.
- Data subject requests. If a data subject writes to us about your workspace, we will not answer for you. We forward the request and help you answer it, using the export and delete controls in the product.
- Assistance. We help you with data protection impact assessments and with prior consultation, to the extent the information is ours to give.
- Breach notice. We tell you without undue delay, and in any case within 72 hours of becoming aware of a personal data breach affecting your workspace, with what we know at the time and what we are doing about it.
- Deletion. On the end of the service, and at any moment you choose, deleting your workspace deletes its calls, transcripts, memory, connections and invitations. Backups roll off on their own schedule and are not restored selectively.
- Audit. We make the information needed to show compliance available on request, and we allow an audit no more than once a year, on 30 days' notice, at your cost, under confidentiality, and in a way that does not put other customers' data at risk.
Sub-processors
You give a general authorisation for the sub-processors below. Each is bound by written terms no less protective than this DPA, and we stay liable to you for what they do.
| Service | What it sees | Why |
|---|---|---|
| Railway (US) | Everything, as our host | Runs the service and the database |
| OpenAI (US) | Live call audio, call transcripts, workspace memory and Jarvey's replies | Hears the room, writes the transcript, the recap and the notes, and answers |
| OpenRouter (US) | Call transcripts, workspace memory and task requests, passed with no data retention to DeepInfra, Together, Baseten, CoreWeave, Parasail or Fireworks, to Microsoft Azure for OpenAI's models, and to TypeSafe | Answers from memory, runs tasks, and takes over when OpenAI or TypeSafe fails |
| TypeSafe | Lines of the call transcript | Decides whether a line was said to Jarvey |
| Soniox | Live call audio | A second transcription, compared with the main one |
| Recall.ai (US) | The call audio and the meeting link | Puts the bot in your Google Meet, Zoom or Microsoft Teams call |
| Deepgram (US) | Live call audio, and the call recording after the call ends | Notices when a sentence has ended, and writes the accurate transcript after the call |
| LiveKit | Audio of calls held on Jarvey's own page | Carries the call |
| Your email, name and picture; the Meet space you create; the calendar you connect | Sign-in, meeting links, and joining the calls you pick | |
| Tavily | The search phrase Jarvey derives from your question | Web search during a call |
| Notion, Trello, Jira, Linear | Only what Jarvey writes, and only if you connect them | Your board |
| Stripe | Your email and payment details | Payment |
| Resend | Your email address and the sign-in code | Sending the sign-in email |
| PostHog (US) | Site usage, cookieless outside the United States: page views, time on a page, how far it was read, the sections and questions opened, link and button clicks, and how quickly the page loaded and responded; in the United States, masked replays of the landing page; setup progress by draft identifier; optional product events and masked replays of ordinary app navigation | Audience measurement, product analytics and usability diagnostics |
| Google Ads (US) | That a browser opened a public page or created an account, the click identifier its own advertisement put in the address, the identifiers its tag keeps in your browser, and that browser's address and user agent; only while ad measurement is on | Measuring which advertisement led to a signup |
| Meta (US) | The same, plus that setup was finished and that a subscription was paid for and the amount, and a one-way hash of the email address on the account and of the account's id (never the address itself), through its pixel and its Conversions API; only while ad measurement is on | Measuring which advertisement led to a signup |
We will give you notice before adding or replacing a sub-processor. If you object on reasonable data protection grounds, tell us within 30 days and we will either propose a change or let you end the affected part of the service without penalty.
Where the data goes
We run in the United States, on Railway. For personal data leaving the EEA, the UK or Switzerland we rely on the Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914), Module Two (controller to processor), which are incorporated into this DPA by reference and completed as follows: you are the data exporter, we are the data importer, the details in "What we process, and why" fill Annex I, the list above fills Annex III, and "Security measures" fills Annex II. For the UK, the ICO's International Data Transfer Addendum applies to those Clauses. Where onward transfer happens between our own sub-processors, Module Three applies.
Security measures
These are the measures we actually run, not an aspiration:
- Access to the production database and to Railway is limited to the people who operate the service, each with their own account.
- All traffic between you, us and every provider above travels over TLS. Database storage is encrypted at rest by our host.
- Google grants are sealed with authenticated symmetric encryption before they are written down, and only the running service holds the key.
- Application logs are redacted before they are written: anything shaped like speech (a transcript, an utterance, a prompt, audio) and anything shaped like a secret is replaced, so meeting content never reaches our log search.
- Sign-in has no password to steal: a one-time code by email, or Google.
- Backups are taken by our host and are subject to the same access limits.
To be exact about the limit: Jarvey is a hosted service that runs the AI for you, so it is not end-to-end encrypted. The running application must be able to read a transcript in order to write a recap from it.
Recording and consent
Jarvey hears the meeting. Getting the consent that the law where your people sit requires is the Controller's obligation, not ours, and the Terms of Service say so in full. We help by making the bot visible in the call and by telling every guest, before they join, that what is said is written down.
Liability and law
The liability limits in the Terms of Service apply to this DPA. It is governed by the law of the United Arab Emirates, save that the Standard Contractual Clauses are governed by the law they name themselves.
Contact
Our contact for data protection questions is privacy@jarvey.io. Ask there for a countersigned copy if your process needs one.