Data processing addendum
If you use Kuno for business purposes and process personal data in doing so, Article 28 GDPR requires a Data Processing Agreement (DPA). Kuno provides a ready-made, GDPR-compliant DPA that you can complete in just a few minutes.
At a glance
- Required under Article 28 GDPR as soon as you use the Kuno device to record or process other people's personal data
- You are the controller, and Kuno is the processor (or sub-processor, if you yourself are acting on behalf of a third party)
- Data processing takes place exclusively in the EU, with no transfers to third countries and no AI training on your data
- Request a DPA in three steps by emailing [email protected]
- The current list of sub-processors can be viewed at any time; changes are announced in advance
A Data Processing Agreement (DPA) sets out, in binding terms, how Kuno processes personal data on your behalf. It is required under Article 28 GDPR as soon as you use Kuno for business purposes and have it process data belonging to third parties.
Who needs a DPA
You need a DPA if you use the Kuno device and the Kuno app to record personal data that doesn’t relate solely to yourself — for example, recordings of conversations with customers, patients, or employees. Purely private use doesn’t require a DPA.
Important: The DPA does not replace the consent of the people you’re speaking with. Secretly recording a non-public conversation is a criminal offense under Section 201 of the German Criminal Code (StGB). Obtain consent before every recording. The visible recording LED on the Kuno device helps you establish transparency.
Roles under the GDPR
- You are the controller for the data you record.
- Kuno is your processor and processes the data solely on your instructions.
- If you yourself are processing data on behalf of a third party, Kuno becomes a sub-processor.
What the Kuno DPA guarantees
- EU data sovereignty: All recordings, transcripts, and processing steps stay within the EU. No data is transferred to third countries.
- No AI training: Your content is never used to train our models.
- Technical and organizational measures (TOMs): Encryption, access controls, and documented security processes are part of the contract.
- Notification obligations: Kuno informs you immediately in the event of a data breach.
- Deletion and return: After the contract ends, your data is deleted or returned on request.
How to complete a DPA
- Email [email protected] with the subject line “DPA” and include your company name and address.
- You’ll receive the pre-filled Kuno DPA as a PDF within a few business days.
- Review, sign, and return it — digital signatures are welcome. The contract is finalized once Kuno countersigns.
Sub-processors
Kuno works with carefully selected, EU-based sub-processors. We send you the current list along with the DPA. We announce new sub-processors in advance so you can exercise your right to object.
Our team is happy to answer any questions about the DPA or data protection at [email protected].