Last updated: 10 November 2026
1. Data residency
All customer data (audio, transcripts, summaries, metadata) is processed and stored exclusively within the EU. No data leaves the EU. Specifically:
- Application hosting & processing: STACKIT (Schwarz Digits), sovereign German cloud, Germany
- Meeting-bot processing: STACKIT, Germany
- Database: MongoDB Atlas on Google Cloud, Netherlands (europe-west4)
- Audio file storage: Google Cloud Storage, Frankfurt, Germany (europe-west3) and Netherlands (europe-west4)
- Transcription: Soniox, Frankfurt, Germany (EU endpoint
api.eu.soniox.com); speaker separation additionally via AssemblyAI on its EU endpoint - AI/LLM inference: via Requesty (EU routing, zero data retention) to Anthropic Claude on AWS Bedrock, Frankfurt (eu-central-1); fallback only on EU regions of AWS Bedrock and Google Vertex
2. Certifications
- ISO/IEC 27001:2022 (information security), certificate no. 00033958, audited annually
- ISO 9001:2015 (quality management), certificate no. 00033957
- Issued by LRQA (UKAS-accredited) to Amberscript Global B.V., the company operating Amber Notes. Valid until 21 April 2028.
3. Technical & organisational measures (TOMs, Art. 32 GDPR)
- Encryption: AES-256 at rest; TLS 1.3 in transit
- Access control: role-based, least-privilege; production access documented + manager-approved; MFA enforced; production and non-production strictly separated (customer data never copied to non-prod)
- Application security: WAF, RASP, CSP headers; protection against SQLi/XSS/RCE/SSRF etc.
- Resilience: redundant data centres, UPS + generators, DDoS protection, continuous monitoring
- Full TOM annex is Appendix 2 of the DPA.
4. Sub-processors & transfers
All content processing and storage runs on EU infrastructure, primarily in Germany and the Netherlands, with AI fallback only on further EU regions (see §1 for exact locations). Full sub-processor register with role and location is Appendix 1 of the DPA.
Where a sub-processor's corporate seat is outside the EEA (e.g. Soniox and AssemblyAI, US), the data itself is processed and stored on that provider's EU-region endpoint with a zero-retention configuration. The corporate domicile is not where your data goes. Any transfer of personal data outside the EU requires advance notice to you and your written approval (DPA Art. 3).
5. AI models & training
Contractual guarantee (DPA Art. 1.5): no personal data, audio, transcripts, summaries or metadata is ever used to train, fine-tune or improve any AI model. All LLM requests route through EU-hosted endpoints configured with zero data retention; no model provider has direct access to customer data.
6. Retention, deletion & export
Data is retained only as long as needed to provide the service. You can export or permanently delete individual meetings or the entire account at any time from the app. Deleted data is first locked, to protect against accidental or malicious deletion, and then removed for good from all servers after a short safety delay; backups follow the data retention policy (DPA Appendix 2, §3.3 and §5.2). Team admins set automatic deletion for the whole organisation: audio as soon as the summary is ready or after 7, 30 or 90 days, and transcripts after 24 hours or after 7, 30 or 90 days. Summaries and action items stay until you delete them. On termination, data is returned on request and then securely destroyed (DPA Art. 6).
7. Recording controls & participant awareness
Amber Notes records only when explicitly started by the user. It never records silently or automatically.
- Online meetings (bot): the notetaker joins as a visible, named participant, so all attendees can see recording is taking place, and it can be removed at any moment. For sensitive conversations this mode is recommended.
- In-person recording (desktop & mobile app): recording is started manually by the user for a single session. As there is no meeting platform through which to notify attendees, the responsibility to inform participants and obtain any required consent rests with the user, who acts as data controller for that meeting, as with any recording device. We provide a consent-notice template and best-practice guidance in onboarding.
As data controller you determine which meetings are recorded and how consent is captured; Amber Notes provides the recording strictly under your control.
8. Incident response
Any data breach is reported to you as soon as reasonably possible, including nature, scope, likely consequences and remediation, with full cooperation on risk assessment and data-subject notification (DPA Art. 5).
Documents
The Data Processing Agreement, with the full sub-processor register (Appendix 1) and the technical and organisational measures (Appendix 2), is available on request: info@amberscript.com