Data Processing Agreement
Last updated 4 September 2026.
Why this exists. A sermon recording reveals religious belief, which the law protects more strictly than ordinary personal data. Your church decides that the sermon is recorded and holds the relationship with the preacher, so your church is the controller and we are the processor. This agreement is the written contract UK GDPR requires between those two roles. We offer it as standard, signed, to any church that wants one — email [email protected] and we will send a copy to sign.
Parties
(1) The Customer — the church or organisation holding the account, acting as Controller; and (2) Nathan Thompson, trading as SermonSignal, of 37 Russell Road, London E4 8HA, United Kingdom, acting as Processor.
It covers personal data processed under the Terms of Service and takes effect when you start using the service. Where it conflicts with the Terms, this agreement wins on data protection matters. It is written to satisfy Article 28(3) UK GDPR.
1. What is being processed, and why
- Subject matter — transcribing sermon recordings and generating short video clips from them.
- Duration — for as long as your account is open.
- Nature and purpose — speech-to-text, and automated selection of passages and captions.
- Types of personal data — audio of speech; transcript text; account email address.
- Special categories — religious belief, inherent in the content of a sermon.
- Data subjects — the preacher; any congregation members audible in a recording; your own staff who hold the account.
You are the Controller for this data. We are the Controller only for your account, billing and marketing data, which sits outside this agreement and is described in the Privacy Policy.
2. What we will do
2.1 Act only on your instructions. We process the data only on your documented instructions — which, in normal use, is the act of uploading a recording and using the service. We will not process it for any other purpose, and will tell you if we believe an instruction breaches data protection law.
2.2 Never train on your content. We do not use your recordings, transcripts or clips to train any model, and we do not permit our providers to do so.
2.3 Keep it confidential. Everyone with access is bound by confidentiality obligations.
2.4 Keep it secure. Appropriate technical and organisational measures under Article 32, including:
- the video file is never uploaded — it is read in your browser, and only an audio-only copy is sent, checked to contain no video track before it leaves;
- only transcript text reaches the AI providers; none of them receives audio or video;
- encryption in transit throughout;
- access to each customer's data scoped to that customer and enforced on the server;
- card details are handled by Stripe and never reach us.
2.5 Sub-processors. You give general written authorisation for those listed in section 3. We will give at least 30 days' notice before adding or replacing one, and you may object; if the objection cannot be resolved you may terminate and receive a refund of the unused portion of the current billing period. Each is bound by data protection terms no less protective than these.
2.6 Help you meet your own duties — responding to requests from individuals exercising their rights, and with security, breach notification, impact assessments and prior consultation.
2.7 Tell you about a breach without undue delay, and in any event within 48 hours of becoming aware of one affecting your data, with the information you need to meet your own obligations.
2.8 Delete or return it. On the end of the service we delete your content. Account records are deleted within 30 days of closure. Billing records are kept for six years because tax law requires it. You can delete your own content at any time from inside the service.
2.9 Let you check. We will make available the information needed to demonstrate compliance and will allow and contribute to audits, on reasonable notice and no more than once a year unless a breach or a regulator requires otherwise.
3. Sub-processors
| Sub-processor | Receives | Purpose |
|---|---|---|
| AssemblyAI | Audio-only copy | Speech-to-text |
| DeepSeek | Transcript text | Clip selection and captions (Fast) |
| Z.ai | Transcript text | Clip selection and captions (Balanced) |
| Moonshot (Kimi) | Transcript text | Fallback capacity |
| Anthropic | Transcript text | Clip selection and captions (Best) |
| OpenRouter | Transcript text | Fallback routing |
| Supabase | Account, transcript and billing records | Database and sign-in |
| Railway | Server runtime | Hosting |
| Stripe | Email, payment details | Payments |
| Cloudflare | Website requests | Marketing site, cookieless analytics |
Which AI provider receives a given transcript depends on the quality setting chosen for that generation. We will confirm the exact provider for any piece of content on request.
4. International transfers
Some sub-processors operate outside the UK and EEA. Transfers are made under the UK International Data Transfer Addendum, or EU Standard Contractual Clauses where applicable, with any supplementary measures required.
5. What you confirm
You confirm that you:
- have the authority to upload the recordings you upload;
- hold any necessary consents, and have given any necessary notices, to the preacher and to any other individual captured in a recording;
- have a lawful basis and, for religious belief, an Article 9 condition — commonly processing by a religious not-for-profit body concerning its own members, or the explicit consent of the individual.
This is not a formality. You are the body that knows the people in the room. We do not, and we cannot obtain those consents on your behalf.
6. Liability, term and law
Liability under this agreement is subject to the limits in the Terms of Service. It lasts as long as we process personal data for you, and sections 2.7, 2.8 and 2.9 survive its end. It is governed by the law of England and Wales, whose courts have exclusive jurisdiction.
Getting a signed copy
Email [email protected] with your organisation's name and we will send a copy for signature and return it countersigned. There is no charge, and you do not need to be a customer yet to ask for one.