Legal

Data Processing Addendum

Last updated October 20, 2026

This addendum forms part of the Terms of Service and governs how Proxy processes personal data on your behalf. If your organization requires a countersigned copy or your own paper, email legal@useproxy.co.

1. Roles

You are the controller of the personal data in your meetings, code and connected tools. Proxy is your processor: we process that data only to provide the service, only on your documented instructions, and never for our own purposes. We do not sell personal data, and we do not use your content to train models.

2. Subject matter, duration, nature and purpose

Subject matter. Providing the Proxy service: joining meetings you designate, answering questions grounded in the code you connect, and drafting follow-up work.

Duration. For as long as your account is active, plus the retention windows in section 7.

Nature and purpose. Recording and transcribing designated meetings; reading the repositories you select; generating answers and draft artifacts; storing the results so your team can review them.

3. Categories of data and data subjects

Data subjects: your personnel and any other participants in meetings Proxy joins.

Categories of personal data:

  • Account data — name, work email, organization, role.
  • Meeting content — audio, transcripts, and anything said in a meeting Proxy attends.
  • Connected-tool content — repository contents and metadata for the repos you select; workspace and channel identifiers for messaging tools you connect.
  • Calendar metadata — where you enable auto-join: event times, titles and attendees, read-only.
  • Usage and diagnostic data — logs, error reports and performance traces.

Proxy is not designed for special-category data. Please do not direct it at systems whose primary purpose is health, biometric, financial-account or government-identifier data.

4. Our obligations as processor

  • Process personal data only on your documented instructions, including for transfers.
  • Bind everyone with access to confidentiality.
  • Maintain the technical and organizational measures in section 5.
  • Engage sub-processors only under section 6.
  • Assist you, so far as we reasonably can, with data-subject requests and with your obligations on security, breach notification and impact assessments.
  • Delete or return personal data at the end of the service, per section 7.
  • Make available the information reasonably needed to demonstrate compliance, and allow audits under section 9.

5. Security measures

  • Tenant isolation. Every record carries a tenant identifier and is enforced at the database layer by row-level security. Each meeting runs in its own isolated sandbox.
  • Encryption. In transit with TLS; at rest by the cloud provider. Third-party access tokens are additionally encrypted with per-purpose application keys.
  • Credential boundary. The sandbox where Proxy works holds no credential that can push code or send a message. Every world-touching action is staged as a draft that a person approves.
  • Least privilege. Repository access is a short-lived, read-scoped token minted per operation. Calendar access, where enabled, is read-only and revocable by your admin.
  • Secrets management. Secrets live in a managed secret store, never in source or logs.
  • Logging and monitoring. Authentication, connection and administrative events are recorded to an audit trail.

See the security overview for current certification status, which we state plainly rather than imply.

6. Sub-processors

You authorize the sub-processors below. We will give notice before adding or replacing one, and you may object on reasonable data-protection grounds.

Sub-processorPurposeLocation
Google Cloud PlatformHosting, database and object storage; Gemini models (live conversation in meetings, research, images, a backup voice)United States
AnthropicThe Claude models: receives the content of a request (a question, the code or conversation it concerns)United States
NangoHolds every access token: your company's installs (GitHub, Slack, Linear), each person's own connections, and your test keys. Encrypted at rest with AES-256-GCM; no token is stored in our own databaseUnited States
Recall.aiJoining meetings and carrying audioUnited States
AssemblyAISpeech-to-text, engaged through Recall.aiUnited States
CartesiaProxy's spoken voice: receives the text Proxy speaksUnited States
E2BIsolated per-meeting compute sandboxesUnited States
Browser UseBrowsers Proxy opens for a task: receives the pages it visitsUnited States
ExaWeb search and reading public pages for research: receives the search textUnited States
ResendSending email: receives recipients and message textUnited States
StripePayments: receives billing contacts and payment details (Proxy never sees a card number)United States
SentryError monitoringUnited States

Meeting audio is heard by Recall.ai and transcribed by AssemblyAI through it; Recall is configured to retain nothing. While Proxy is in a meeting the transcript is also processed by the model vendors above (Anthropic, and Google for live conversation) in order to answer. None of them is permitted to train on your content under the terms we use them on.

7. Retention, return and deletion

  • A meeting's transcript, notes, action items, threads and published artifacts are kept for your company's retention period (30 days unless you set 7 to 90) and then permanently deleted by a nightly job. Usage records and the audit trail, which hold no meeting content, are kept.
  • The working copy of your code is a rebuildable cache and is discarded when a sandbox ends.
  • On written request, or within 30 days of termination, we delete or return personal data, except where law requires us to keep it.
  • Backups age out on their own cycle; deleted data stays isolated until it does.

8. International transfers

Data is processed in the United States. Where you transfer personal data from the EEA, UK or Switzerland, the parties incorporate the European Commission's Standard Contractual Clauses (module two, controller to processor), with the UK Addendum where the UK GDPR applies. Contact legal@useproxy.co for a signed copy.

9. Audits

On reasonable notice, no more than once a year, and subject to confidentiality, we will respond to a security questionnaire and provide the documentation reasonably needed to verify this addendum. On-site audits are by agreement.

10. Personal-data breach

We will notify you without undue delay, and in any case within 72 hours of becoming aware of a personal-data breach affecting your data, with the information available at the time and updates as we learn more.

11. Order of precedence

Where this addendum conflicts with the Terms of Service, this addendum controls for the processing of personal data.

Proxy is an early-stage company and this document reflects how the product actually works today rather than an aspiration. If your procurement process needs changes to this paper, we would rather negotiate it than have you sign around it.