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Data Processing Agreement

Effective Date: April 11, 2026 | Last Updated: April 25, 2026

1. Parties and Scope

This Data Processing Agreement (“DPA”) is entered into between Trade Digital LLC d/b/a Interprivo (“Processor”) and the customer entity that has accepted Interprivo's Terms of Service (“Controller”). This DPA governs Interprivo's processing of Personal Data on behalf of the Controller in connection with the Interprivo platform.

2. Definitions

  • Personal Data: Any information relating to an identified or identifiable natural person, as defined under GDPR Article 4(1).
  • Processing: Any operation performed on Personal Data, including collection, storage, transmission, and deletion.
  • Sub-processor: A third party engaged by Interprivo to process Personal Data on behalf of the Controller.
  • Data Subject: An identified or identifiable natural person whose Personal Data is processed.

3. Processing Instructions

Interprivo processes Personal Data only on the documented instructions of the Controller, including for real-time interpretation, session management, billing, optional telephony, optional recordings, and related support operations needed to deliver the contracted service.

4. Categories of Personal Data Processed

  • Account identifiers such as name, email address, organization membership, and user ID.
  • Live voice audio processed in real time for interpretation and telephony features.
  • Stored transcripts, summaries, speaker metadata, flagged terms, and usage records.
  • Operational telemetry such as provider-event logs, escalation metadata, and health diagnostics.
  • Billing information and payment references managed through Stripe.
  • Optional call recordings or recording URLs when recording-related features are enabled.

5. Technical and Organizational Security Measures

Interprivo implements technical and organizational measures designed to protect Personal Data, including:

  • Encryption in transit for application traffic and provider integrations.
  • Access controls, tenant isolation, and row-level security for organization data.
  • Authenticated API access and controlled service-role operations.
  • Operational logging, alerting, and incident-response procedures.
  • Dependency updates, monitoring, and security hardening on core infrastructure.

6. Sub-processors

The following public list reflects the providers currently wired into the product codebase. Some are always on, while others are feature-conditional and only process data when the related capability is enabled.

Sub-processorRoleData InvolvedWhen Used
InsForgeApplication database, authentication, storage, and server-side functionsAccount details, session data, transcripts, summaries, usage records, private filesCore platform for every workspace
VercelHosting, edge delivery, cron execution, and deployment infrastructureApplication traffic, request metadata, deployment and runtime logsCore website and API delivery
LiveKitRealtime media transport, room signaling, and optional recording orchestrationLive audio packets, room and session metadata, optional recording artifactsBrowser and live-room interpretation
DeepgramSpeech-to-text transcription and language detectionLive audio, transcript text, language and confidence metadataSpeech interpretation pipeline
AnthropicPrimary large-language-model translation and summarizationTranscript excerpts, prompts, glossary context, generated summariesAI translation and intelligence features
OpenAIFallback LLM translation and selected AI featuresTranscript excerpts, prompts, glossary context, generated summariesFallback or feature-specific AI tasks
ElevenLabsSpeech synthesis for translated audio outputTranslated text and voice selection settingsSpoken audio output is enabled
VapiVoice agent orchestration, PSTN call control, and end-of-call reportsCall metadata, phone numbers, audio or transcript report payloadsPhone-based interpreting flows
TwilioDedicated phone number provisioning and PSTN carrier servicesBusiness phone numbers, caller and callee metadata, routing dataDedicated numbers or Twilio-backed calling are enabled
StripeSubscription billing, checkout, invoices, and payment method vaultingBilling identity, plan selection, invoices, payment referencesPaid plans, checkout, or invoicing
UpstashRedis caching, rate limiting, and queued job deliveryCache keys, rate-limit identifiers, retry job payloadsRedis or QStash-backed features are configured
ResendTransactional email delivery and contact or audience managementRecipient emails, invite or contact content, lifecycle email dataEmail and contact capture flows are used
SentryError monitoring and diagnosticsException payloads, request context, debugging metadataError monitoring is enabled
PostHogProduct analytics and usage telemetryClient identifiers, page views, product usage eventsAnalytics is enabled
SlackOperational alerts, low-NPS notifications, and human escalation dispatchAlert text, escalation metadata, feedback summariesSlack webhooks are configured
PagerDutyIncident alerting and on-call escalationCritical incident payloads and operational contextPagerDuty routing is configured
hCaptchaBot and abuse protectionIP, device, and browser interaction signals for risk scoringProtected signup or form flows

The Controller will be notified of material changes to this public list before a newly added sub-processor begins handling Customer Personal Data.

Interprivo also publishes a shared service inventory used for legal, operations, and deployment review so the same source backs every disclosure surface.

7. Data Subject Rights

Interprivo provides mechanisms to help Controllers respond to data subject requests.

  • Access / Portability: Data export tools are available in the application for supported records.
  • Erasure: Controllers may delete stored account and session data, subject to legal retention obligations.
  • Rectification: Profile and organization data can be updated by authorized users.
  • Objection / Restriction: Contact privacy@interprivo.net.

8. Data Retention and Deletion

By default, live audio is processed in transient memory for interpretation rather than intentionally stored as raw audio by Interprivo. Transcripts, summaries, usage records, and other stored workspace data remain available until deleted by the Controller or removed during account deletion, subject to applicable legal retention requirements. If the Controller enables recording-related features, audio recordings or recording URLs may also be retained until deleted.

9. International Data Transfers

Some sub-processors used by Interprivo operate in the United States or across multiple regions. Where Personal Data is transferred from the EEA, UK, or Switzerland to jurisdictions without an adequacy decision, Interprivo relies on contractual safeguards such as Standard Contractual Clauses or equivalent lawful transfer mechanisms.

10. Breach Notification

In the event of a confirmed Personal Data breach affecting Controller data, Interprivo will notify the Controller without undue delay and provide information reasonably necessary for the Controller to meet its own legal obligations.

11. Contact

For DPA-related inquiries, a signed copy request, or a data-protection concern, contact privacy@interprivo.net.

Last updated: April 25, 2026. This DPA is incorporated by reference into Interprivo's Terms of Service and Privacy Policy.