GDPR and the European Union
GDPR practices
Distronode Corporation • Last Updated: October 10, 2026
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01. Who We Are To You
Distronode Corporation is a Canadian company, incorporated federally under the Canada Business Corporations Act. We have no establishment in the European Union: no office, no branch and no staff there.
For the personal data inside your workspace, the callers, contacts, transcripts, messages and meetings your receptionist handles, you are the controller and we are your processor. Our Data Processing Agreement sets those terms. For your own account, your sign-in, your subscription and the record of how you use this site, we are the controller.
We have not appointed a representative in the Union under article 27, and we would rather say so plainly than let the absence read as an oversight. The decision sits with counsel. Every request under this page goes to legal@distronode.com, which reaches Sean Dean, our founder and the person accountable for privacy here.
02. Where A European Workspace Runs
In the Union
Stored in Frankfurt (Amazon Web Services, eu-central-1), with the website on the same host. Speech runs on European endpoints, the call's language model in europe-west4, and the media, signalling and voice agent in Frankfurt. Error diagnostics (Sentry, Germany), telemetry (New Relic, EU) and encrypted backups (Cloudflare's EU jurisdiction) also stay in the Union. So do sign-in, the phone-number directory, workspace membership, our own subscription records, the shared operational state and the scheduled jobs for a European workspace.
What still leaves the Union
In the United States: payment records at Stripe, and a frozen earlier copy of the sign-in, directory, membership and number routing records, kept so we can roll back, and in our encrypted backups. Also outside the Union: Cloudflare's global edge, Postmark email, our credential key and secrets store (Google, global), the optional video avatar, and push notifications (identifiers only). Our Terms list each item.
Telephony: a call on a European number we issue you arrives through Twilio's Dublin gateway and is answered in Frankfurt, and calls you place start in Frankfurt. A call on a United States number we issue you is answered in Frankfurt too, after crossing United States phone networks; a number on your own carrier account is answered in the United States. Texts on Telnyx numbers use Telnyx's United States interface. Telnyx stores its records in Canada, but your outbound calls' records in Germany since October 2026. Support requests go to our desk in Canada.
03. Transfers
Your transfer to us rests on the European Commission's adequacy decision for Canada, Decision 2002/2/EC, which covers Canadian commercial organisations subject to PIPEDA. We are one, so the transfer from you to us needs no separate clauses.
What we send onward to the United States is our own transfer rather than yours, and it is the exposed leg. It rests on the standard contractual clauses in each vendor's data processing terms, Module Two where we are the controller and Module Three where we pass your data onward as your processor. Google LLC also holds a Data Privacy Framework certification.
We are not eligible for that Framework ourselves. It is open to organisations under the jurisdiction of the United States Federal Trade Commission or Department of Transportation, and a Canadian company is neither, so we do not claim it.
We have written a transfer impact assessment for that leg, covering the supplementary measures and United States surveillance law. It is held in our records and we provide it to a customer under the Data Processing Agreement.
04. The AI Act
We are the provider; the business that puts the receptionist on its line is the deployer.
What we do as the provider
Every call opens with a fixed sentence, in the receptionist's language, saying it is an automated assistant and that the call is transcribed. European workspaces cannot switch it off: the dashboard toggle is locked and the interface refuses the request, and our fallback receptionist discloses too. It is written in English, French, German, Spanish, Dutch and Italian; other languages open in English. We run no emotion recognition: the avatar only renders and lip-syncs, and sentiment comes from the transcript, never the voice.
What the deployer owes
Telling people they are speaking to a machine is the deployer's duty too, as is the lawful basis for outbound calls: most member states require prior consent for automated marketing calls, and an opt-out list is not consent. National recording law governs what is kept, here a transcript and a summary.
What it can and cannot do
It answers from the business's knowledge base and instructions, transfers calls, takes messages and books meetings. It makes no decisions with legal effect: it does not price, approve, refuse or score anyone. It cannot reach another business's workspace, a boundary the database enforces. It can be wrong, and a caller can always ask for a person.
05. Rights
If you hold a workspace with us
You can take your data out and you can delete the account yourself. In the dashboard, under Billing, Export Workspace Data has an Export Data button that returns contacts, calls, transcripts, messages, meetings and settings as JSON.
Below it, the Danger Zone has Delete Account, which asks for your password again on purpose so that an unattended session cannot destroy an account.
A request you send us by email is answered without undue delay and within 30 days. Asking us to erase your data, or deleting the account yourself, starts the erasure immediately.
If a business called you
The business that called you is the controller of the record of that call, not us. It decides why the call was made and what is kept, so your request belongs with it first. It can act on your request inside its own workspace, and we assist it under our Data Processing Agreement.
If you cannot reach that business, write to legal@distronode.com and we will pass the request to the controller. We will not answer it in their place, because the decision is theirs to make, and telling you that is better than leaving you waiting for an answer that is not ours to give.
06. Retention
Each window is named with what enforces it; where there is none, we say so.
- Call audio
- None is captured. A call leaves a transcript and a summary.
- Transcripts, summaries and call records
- Kept while the account is active, or for 30, 90 or 365 days if the workspace sets a period. A sweep then erases transcripts, summaries and AI analysis, keeping the call record so counts and billing add up.
- Contacts, messages, meetings and knowledge base
- Kept until you delete them; a set period also erases older message text.
- Sign-in history
- 90 days.
- Support correspondence
- 365 days after opening, longer while a request is still open.
- Registration documents
- Deleted 30 days after the country's last number is released or the registration withdrawn, and immediately when the account is deleted.
- Backups
- 14 daily and 8 weekly encrypted copies per region, encrypted before they leave the region.
07. Breaches
We keep a register of confidentiality incidents and a written procedure behind it, and the person accountable for privacy maintains both.
Where a breach affects your workspace we notify you without undue delay, and in any case within 48 hours of confirming it, with the information you need to meet your own notification duties. That is the commitment our Data Processing Agreement makes.
Where we are the controller, we notify the supervisory authority within 72 hours of becoming aware of a breach, unless it is unlikely to result in a risk to people. Awareness is the moment we have reasonable certainty that one has occurred, not the moment we finish diagnosing it.
Having no establishment in the Union, we have no lead supervisory authority. A notification therefore goes to the authority of every member state whose residents are affected, which means working out where affected people live inside the 72 hours rather than after them.
08. Cookies
Nothing that needs consent runs before you give it. Analytics and advertising storage start denied, for every visitor and on every one of our sites, and stay denied until you accept.
Today the choice is accept or decline, not one purpose at a time. We would rather name that limit than describe a control we do not ship.
Cookie preferences, in the footer of every page, reopens the choice whenever you want it. Withdrawing consent takes effect from the moment you withdraw it and does not undo what was done while it was given.
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