Data Processing Agreement
Available for signature
Distronode Corporation • Last Updated: October 3, 2026
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01. What This Is
A Data Processing Agreement (DPA) is the contract that governs how we handle personal information on your behalf when you use District AI. This page is a plain-language summary of the DPA we offer to customers. It is written to be readable by a small-business owner, not only by a lawyer.
The signed DPA sits alongside our Terms of Service and Privacy Policy. Where the DPA and the Terms differ on the handling of personal information, the DPA governs.
02. Roles
You (the customer)
You decide why and how personal information is collected through your receptionist. Under privacy law you are the controller, and under PHIPA you may be the health information custodian. You are responsible for having a lawful basis and for giving your callers the notice and consent your situation requires.
Us (Distronode Corporation)
We act as your processor and service provider. We handle personal information on your instructions to deliver the service, and we do not decide the purposes of your processing. Distronode Corporation is a Canadian corporation, federally incorporated under the Canada Business Corporations Act, with our founder and CEO, Sean Dean, accountable for privacy.
03. Scope of Processing
| Element | What it covers |
|---|---|
| Subject matter | Providing the District AI voice receptionist and related messaging, CRM, and scheduling features. |
| Duration | For as long as your subscription is active, plus the limited period needed to delete or return data afterward. |
| Nature and purpose | Answering, routing, transcribing, and summarizing calls; sending and receiving messages; enriching contacts where you enable it; and billing. |
| Types of personal data | Caller phone numbers, call audio (processed while a call is in progress and not stored) and transcripts, contact and CRM records, message content, appointment details, and account and billing information. Where you register for a telephone number in a country whose regulator requires it, also the registration documents you provide: business registry extracts, proofs of address and, for registrations in an individual's name, government identity documents such as a passport or national identity card. |
| Categories of individuals | Your callers and customers, your contacts, and your own team members who use the workspace. |
04. Our Commitments as Processor
Instructions
We process personal information only to provide the service and on your documented instructions, including workspace settings. We neither sell your content nor use it for our own purposes, but may use aggregated, de-identified statistics identifying neither you nor any individual.
Confidentiality
Staff handling your data are bound by confidentiality; production access is scoped and least-privilege.
Security
We keep appropriate technical and organizational safeguards: TLS 1.2+ in transit; provider encryption at rest, plus Google Cloud KMS for stored third-party credentials; PostgreSQL row-level tenant isolation; managed secrets; authentication rate limiting.
Sub-processors
We use vetted sub-processors, remain responsible for them, keep a current list and give at least 30 days' notice before adding or replacing one, so you can object.
Individual requests
We help you meet access, correction, deletion and portability requests with product tools and direct support; help beyond the tools may be charged reasonably when requests are excessive. We redirect people asking about data you control to you and answer only if you ask.
Breaches
We keep incident logs and will notify you without undue delay, and within 48 hours of confirming a personal-data breach affecting your workspace, with the information your notification duties require.
Deletion
On termination or request we delete or return your workspace data and, on request, confirm deletion in writing. Calls are not recorded, so there is no call audio to delete or return.
Audits
We keep processing records and cooperate with your reasonable audit and information requests, and with supervisory authorities where law requires. Documentation, written answers and third-party reports come first. Any further audit is limited to once per twelve months, on at least 30 days' written notice, in business hours, at your cost, under confidentiality, in an agreed scope, never touching other customers' data.
05. Your Commitments as Customer
- Have a lawful basis for the personal information you collect, and give your callers the notice and, where required, the consent your situation calls for.
- Use call transcription and outbound calling or messaging in line with the laws that apply to you and your callers, including the consent rules that apply to recording or transcribing a call and anti-spam laws such as CASL in Canada and the TCPA in the United States. For callers in the European Union or the United Kingdom, that includes the prior consent article 13 of the ePrivacy Directive requires for automated marketing calls, and whatever consent national law requires to record or transcribe a call.
- Configure your workspace (transcript retention, enrichment, and access) to match your own policies.
- Keep your team's accounts secure and limit access to those who need it.
- Give us only lawful instructions, and indemnify us for processing we carry out on an unlawful one.
06. International Transfers
Outside Canada, Europe and Asia-Pacific, AI processing runs in the United States.
Europe: The live-call language model runs in europe-west4; the media plane, TURN, signalling bus and voice agent in eu-central-1; and speech on our vendors' European endpoints. Calls to a European number we issued arrive through Twilio's Dublin gateway and are answered in Frankfurt; calls your workspace places originate in Frankfurt.
Canada: The language model runs in Montreal (northamerica-northeast1) on every engine except the realtime one (United States, us-east4). New Canadian workspaces start on an engine that also runs speech recognition and synthesis in Montreal; other engines run those legs in the United States.
Asia-Pacific: the same, in Singapore.
Your outbound calls and calls on our numbers are handled in your region, a Canadian workspace's Twilio calls via the United States. A number on your own carrier account is answered in the United States. Our claim stops at the handoff to the carrier.
Support requests go to one site in Canada serving all four regions, so unless your workspace is Canadian they are held outside your region. Cross-border transfers rely on recognized mechanisms, including standard contractual clauses and applicable adequacy decisions, together with the technical and organizational safeguards in this DPA.
The data residency map shows each data type's location.
07. Sub-processors & How to Sign
Our current sub-processors, with their purpose, data category, and region, are listed on the sub-processor page. Every addition, replacement and removal is published there as a dated change-log entry, which is the notice, and you can ask legal@distronode.com to be told by email instead, with 30 days' notice before a change. Either way you can object on reasonable data-protection grounds.
Download the executable DPA below, or contact us to have it countersigned (tell us your legal entity name):
Or email legal@distronode.com directly. The signed DPA incorporates the EU Standard Contractual Clauses (Module Two) and the UK Addendum by reference for EEA/UK transfers; where the Clauses or the Addendum conflict with the DPA, the Clauses or the Addendum prevail.