Data Processing Addendum

Version 1.1 · 15 August 2026

This is the DPA we offer for signature. It is unusually short, and the reason is structural rather than stylistic: your dictated audio and text never reach us, so there is very little for us to process on your behalf.

Read this first. The personal data you are most likely worried about — what your clients or patients said — is never transmitted to us and never exists on our systems. Recognition happens on each Mac. What this Addendum covers is the small administrative remainder: a licence key, a hashed device identifier, and any support correspondence you choose to send us.

If your organisation requires its own DPA template instead, send it to us and we will work from yours.

1. Parties and scope

This Addendum forms part of the Terms of Service between Altypist (“Processor”) and the organisation licensing Altypist (“Controller”, “you”). It applies where and to the extent that Processor processes personal data on Controller's behalf in connection with the Altypist software and its licensing.

Where the parties' obligations under applicable data protection law conflict with this Addendum, that law prevails.

2. Roles

For the data described in Annex A, Controller is the controller and Processor is the processor. Processor processes that data only on Controller's documented instructions, of which this Addendum and the Terms are the standing instruction.

For the dictated content itself, Processor is neither controller nor processor, because it never receives it. Controller remains solely responsible for that content, which resides on Controller's own devices.

3. Subject matter, nature, purpose and duration

4. Processor obligations

Processor shall:

5. Sub-processors

Controller gives general authorisation for the sub-processors in Annex B. Processor will give Controller reasonable prior notice of any addition or replacement, and Controller may object on reasonable data protection grounds; if the objection cannot be resolved, Controller may terminate the affected licence and receive a pro-rata refund of any prepaid, unused fees.

Processor remains responsible for its sub-processors' performance of these obligations.

6. International transfers

Annex B states where each sub-processor operates. Two things about it are worth reading before signing rather than discovering later.

Processor is established in the Republic of Serbia, which has no adequacy decision under the UK or EU GDPR. Transfers from the EEA or the UK to Processor therefore rely on the Standard Contractual Clauses or the UK International Data Transfer Addendum, which section 6 incorporates below. Processor's sub-processors are established in the United States and rely on their own transfer mechanisms, including the EU-US Data Privacy Framework where they are certified to it.

What this covers is narrow, and that is the point: a licence key, a hashed device identifier, and whatever Controller chooses to write to support. Dictated audio and text are not transferred anywhere at all — they are processed on Controller's own devices and never reach Processor or any sub-processor, so no transfer mechanism applies to them.

Controller should still avoid putting a data subject's personal data into support correspondence where it is not needed to answer the question. That is ordinary hygiene with any vendor's mailbox, not a limitation specific to this one.

Where a transfer requires them, the parties will enter into the applicable Standard Contractual Clauses or UK International Data Transfer Addendum, which are incorporated by reference and prevail over this Addendum in the event of conflict.

7. Data subject rights

Processor will, on Controller's request, provide the information it holds against a licence, correct it, or delete it. Because the record is a licence key, a hashed device identifier and timestamps, most such requests can be answered in full within a few working days. Deleting a licence record also deactivates the licence, so Processor will confirm before doing so.

Processor cannot identify a data subject from a hashed device identifier, and neither can anyone else — the hash is one-way and the underlying identifier is never transmitted.

8. Deletion and return

On termination or expiry, Processor will delete Controller's licence and activation records within 90 days, except where retention is required by law, and will delete support correspondence on request. Because Processor holds no dictated content, there is nothing further to return.

9. Audits

Processor will make available the information reasonably necessary to demonstrate compliance with this Addendum, including the architecture documentation. Given that the software runs entirely on Controller's hardware, Processor holds no service for a conventional audit to examine; Controller may verify the software's behaviour independently, and the architecture page describes how. Where Controller nonetheless requires an audit, Processor will cooperate on reasonable notice, no more than once a year absent a specific concern, at Controller's cost.

Processor does not hold a SOC 2 or ISO 27001 report and does not claim to.

10. Liability and term

This Addendum takes effect when the Terms do and continues while Processor processes personal data on Controller's behalf. Liability under this Addendum is subject to the limitations in the Terms, except where applicable law does not permit that.

Annex A — Data processed

CategoryDataData subjects
Licence recordLicence key, tier, number of seats, status, an internal note such as an order reference, timestamps, and any subscription end dateNone directly identifiable
Activation recordAn instance identifier and a SHA-256 hash of the Mac's hardware UUID, with the time of activationController's personnel, only indirectly and not identifiable by Processor
Support correspondenceEmail address, message content, and anything else Controller chooses to includeWhoever writes in
Payment confirmationConfirmation that payment succeeded, and the billing email address supplied to the payment providerController's billing contact

Not processed, at all: dictated audio, transcribed or formatted text, custom vocabulary, which applications are dictated into, usage analytics, or any telemetry. No such data is transmitted by the software.

Annex B — Sub-processors

Sub-processorPurposeLocation
Cloudflare, Inc.Website hosting, licence server (Workers) and licence database (D1)United States, with global edge processing
Google Ireland Ltd / Google LLCThe support mailbox (Google Workspace)United States and the EU
Lemon SqueezyMerchant of record: taking payment, VAT and receiptsUnited States

Hugging Face hosts the recognition model that each Mac downloads once. That is a file download initiated by Controller's device and carries no personal data, so it is not a sub-processing arrangement.

Annex C — Security measures

Signing

Write to privacy@altypist.com with your organisation's details and we will return a countersigned copy, or work from your own template if you prefer.

Processor: ALTYPIST DOO Beograd, Milutina Milankovića 7 DJ, 11070 Belgrade, Republic of Serbia. PIB 115878048 · registration number 22323695. Data protection contact: privacy@altypist.com.