Skip to content

Legal

DPA

Last updated 25 September 2026

This document is a working draft published for transparency about how the product is built. It has not completed legal review and is not a contract. The executed agreement for your account is the one you sign.

Roles

For the data of the prospects and customers your motions engage, you are the controller and we are the processor. For account data about your own team, we are the controller.

Instructions

We process data on your documented instructions, which are the configuration of your account: the systems you connect, the audiences you approve, the motions you launch, the commercial authority you grant, the communication policy you set and the retention you choose.

A motion's definition is part of those instructions. It is a record of what you authorised, which is why the platform enforces it rather than a prompt.

We do not process your data for any other purpose, and we do not use it to train models made available outside your account.

Security measures

Encryption in transit and at rest. Isolation between organisations enforced at the record level — cross-organisation reads are not a permission anybody can be granted.

Each agent acts under its own identity, so every message and every call is attributable to a specific agent and version rather than to a shared credential.

Credentials for connected systems are held in a vault, scoped per connection, injected at call time and never placed in an agent's context. Redacted from logs, traces and error messages.

Communication policy — hours, caps, disclosure, suppression, consent — is evaluated deterministically before any message is sent or any call placed.

Commercial authority is evaluated before an offer is made, in addition to the underlying runtime's tool permissions. Both have to pass.

Access to production restricted, time-bound, logged and reviewed. Every consequential commercial action recorded with its actor, agent version, inputs, the policy applied and the result.

The agent layer

An agent engages only through channels and capabilities granted to it, and only within the commercial authority configured. There is no separate, broader path for agent access — a second permission model would diverge from the first and the divergence would be a breach.

Agreeing contractual terms, committing a service level, signing, taking payment and contacting a person without a permitting consent state are refused to every agent on every plan.

Claims about your company come from content you approved. An agent cannot compose a new claim, and where two approved sources conflict it stops and escalates.

Content reaching the system — replies, attachments, event payloads — is data and cannot instruct an agent.

An approval cannot be granted by an agent or by an API key. The point of an approval is that a person decided.

Sub-processing

We use the sub-processors listed on the subprocessors page, which for this product includes telephony and model providers. We give notice before adding one, and each is engaged under terms no weaker than these, including the prohibition on training.

Assistance and audit

We assist with data subject requests, impact assessments and incident notification within the timelines your agreement sets. Because requests from the people you contacted come to you, that assistance is oriented towards helping you answer them — including producing the record of what was sent or said to a specific person.

Because engagement, approvals and authority decisions are recorded with their actor as they happen, most audit questions about a specific conversation can be answered from the record rather than by investigation.

Deletion and return

On termination, data is returned or deleted at your election within the period your agreement sets. Export of opportunities, motions, engagement history, transcripts and attribution records remains available throughout the term and during any wind-down.

Make sure every opportunity gets a next action.

Let AI handle the repetitive engagement, keep follow-up moving, and bring your team in when a customer needs a real conversation.

Agents identify themselves on every call · Nothing commits without you · [email protected]