Data Processing Agreement

Last updated: 28 February 2026

This Data Processing Agreement ("DPA") forms part of the agreement between LingoVoice (the "Processor"), operated by Lingo Service Translations, and the organisation using the LingoVoice platform (the "Controller"). It sets out the terms under which LingoVoice processes personal data on behalf of the Controller, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Introduction

LingoVoice provides a real-time interpreting and translation platform. In the course of delivering this service, LingoVoice acts as a data processor on behalf of the organisation (the data controller) under UK GDPR. This DPA governs LingoVoice's obligations regarding the processing of personal data and ensures appropriate safeguards are in place to protect the rights of data subjects.

This agreement applies to all personal data processed through the LingoVoice platform, including user account information, message text, audio data transmitted during interpreting sessions, and payment details. LingoVoice processes personal data only on documented instructions from the Controller, unless required by UK law to do otherwise.

2. Definitions

• "Personal Data" means any information relating to an identified or identifiable natural person, as defined under UK GDPR Article 4(1). In the context of LingoVoice, this includes names, email addresses, message content, audio recordings, and IP addresses.
• "Processing" means any operation or set of operations performed on personal data, including collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, combination, restriction, erasure, or destruction.
• "Sub-processor" means any third party engaged by LingoVoice (the Processor) to process personal data on behalf of the Controller. A full list of sub-processors is provided in Section 4 below.
• "Data Subject" means the identified or identifiable natural person to whom the personal data relates, including platform users, guests, and any person whose data is processed during interpreting sessions.

3. Scope of Processing

LingoVoice processes personal data solely for the purpose of providing real-time interpreting and translation services. The scope of processing includes:

• Text translation — Source text entered by users is transmitted to translation providers (DeepL, Google Cloud, Azure, OpenAI) for real-time translation. Text is processed in transit and is not permanently stored by sub-processors.
• Speech-to-text (STT) — Audio recorded by users during voice sessions is transmitted to STT providers (OpenAI Whisper, Google Cloud Speech, Azure) for transcription. No audio is persistently stored. Audio data exists only for the duration of the API call and is discarded immediately after transcription.
• Text-to-speech (TTS) — Translated text is transmitted to TTS providers (ElevenLabs, Google WaveNet, Azure Neural) to generate spoken audio. Generated audio is streamed to the client and not stored.
• User account management — Account information (name, email, hashed password) is stored in the LingoVoice database to provide authentication and platform access.
• Email communications — Email addresses and names are shared with our email provider (Resend) to deliver transactional emails such as welcome messages, password resets, and payment confirmations.

LingoVoice does not sell personal data, use it for advertising, or process it for any purpose beyond the services contracted.

4. Sub-processors

LingoVoice engages the following sub-processors to deliver its services. The Controller is deemed to have given general written authorisation for the use of these sub-processors. LingoVoice will notify the Controller of any intended changes, giving the Controller the opportunity to object.

All sub-processors are bound by data processing agreements that require them to protect personal data in accordance with UK GDPR. For US-based sub-processors, transfers are governed by Standard Contractual Clauses (see Section 9).

5. Data Retention

LingoVoice operates a minimal-retention approach to personal data processed during interpreting sessions:

• Session messages — Messages are stored in the database for the duration of an active room session. When all participants leave and the room empties, messages are permanently deleted. There is no long-term message archive.
• Audio data — No audio is stored at any point. Audio is streamed to speech-to-text providers in real time and discarded immediately after transcription. Neither LingoVoice nor its sub-processors retain audio recordings.
• Transcripts — Session transcripts are only retained if explicitly exported by the user. Exported transcripts are the responsibility of the user and are not stored on the LingoVoice platform after export.
• Account data — User account information (name, email, hashed password) is retained for the duration of the account. Users may delete their account at any time through the platform, which permanently removes all associated personal data.
• Payment records — Transaction records are retained as required by UK financial regulations (typically 6 years) and are not deleted upon account closure.

6. Security Measures

LingoVoice implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including:

• Encryption in transit — All connections are secured with TLS 1.2 or higher. HTTPS is enforced across the entire platform, including all API endpoints and WebSocket connections. No unencrypted data transmission is permitted.
• Password security — User passwords are hashed using bcrypt with 12 rounds. Passwords are never stored in plaintext or reversible formats.
• Token security — JWT access tokens expire after 15 minutes. Refresh tokens are rotated on each use and stored as irreversible SHA-256 hashes. Compromised token data cannot be used to reconstruct valid credentials.
• Encrypted volumes — Database infrastructure uses encrypted volumes at rest, ensuring data remains protected even in the event of physical media compromise.
• Access controls — Personnel access to personal data is limited on a strict need-to-know basis. Administrative access requires authenticated sessions with role-based permissions.
• Rate limiting — API endpoints are protected by rate limiting to prevent brute-force attacks and abuse. Authentication endpoints have stricter limits than general endpoints.
• Security reviews — We conduct periodic security reviews and vulnerability assessments across our infrastructure and application code.

7. Data Subject Rights

LingoVoice assists the Controller in fulfilling its obligations to respond to Data Subject requests under UK GDPR. Data subjects have the following rights:

• Right of access — Data subjects may request a copy of all personal data held about them. Users can view their account data directly through the platform.
• Right to rectification — Data subjects may request correction of inaccurate or incomplete personal data. Users can update their profile information directly through the platform.
• Right to erasure — Data subjects may request deletion of their personal data. Users can delete their account through the platform, which permanently removes all associated data. Requests can also be made via email.
• Right to data portability — Data subjects may request their personal data in a structured, commonly used, and machine-readable format for transfer to another service.
• Right to restriction of processing — Data subjects may request that processing of their personal data be restricted in certain circumstances.
• Right to object — Data subjects may object to the processing of their personal data in certain circumstances.

To exercise any of these rights, data subjects may contact us at dpa@lingovoice.ai or support@lingovoice.ai. We will respond to all valid requests within one calendar month.

8. Breach Notification

In the event of a personal data breach, LingoVoice commits to the following:

• LingoVoice will notify the Controller without undue delay and in any event within 72 hours of becoming aware of a personal data breach, in accordance with UK GDPR Article 33.
• Notification will include: the nature of the breach, the categories and approximate number of data subjects affected, the likely consequences of the breach, and the measures taken or proposed to address it.
• LingoVoice will cooperate fully with the Controller in investigating and mitigating the breach, and will provide all reasonable assistance in notifying the Information Commissioner's Office (ICO) and affected data subjects where required.
• LingoVoice maintains an internal breach register documenting all security incidents, their effects, and the remedial actions taken.

9. International Transfers

LingoVoice's primary infrastructure is hosted in the United Kingdom (DigitalOcean London region). However, certain sub-processors are based in the United States. LingoVoice ensures that all international transfers of personal data comply with UK GDPR requirements:

• UK and EU sub-processors — DeepL (Germany), Google Cloud (EU), Microsoft Azure (UK London), and DigitalOcean (UK London) process data within jurisdictions that provide adequate protection under UK GDPR.
• US sub-processors — OpenAI, ElevenLabs, and Resend are based in the United States. Transfers to these sub-processors are protected by Standard Contractual Clauses (SCCs) as approved by the UK government, supplemented by additional technical and organisational safeguards.
• UK-US Data Bridge — Where applicable, transfers also benefit from the UK Extension to the EU-US Data Privacy Framework, which provides an additional legal basis for transfers to certified US organisations.
• No other transfers — No personal data is transferred outside the UK, EU, or United States.

10. Contact

For questions about this Data Processing Agreement, to request a signed copy of this DPA, or to exercise any data protection rights, please contact us: