GDPR: roles, bases and how to exercise your rights

WitUp Ltd, Company No. 16572774, 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom, is the controller for account, plan and billing data.

For the content you protect (the counterparties you invite, the documents you register, what is said in a meeting you protect) you are the controller and WitUp Ltd acts as your processor, on your instructions. Our sub-processors are named in the Privacy Policy, with the region each one operates in.

Providing the service to an account holder: performance of a contract (Art. 6(1)(b)).

Binding a signatory to an agreement, and recording the evidence of that act, including the timestamp, IP address and user agent: performance of a contract entered into at the signatory's own request (Art. 6(1)(b)), and our legitimate interest, and yours, in evidence that can actually be relied upon (Art. 6(1)(f)).

Recording a protected meeting: the explicit, separate consent of every participant, collected before anything is captured (Art. 6(1)(a)). Without it the witness records nothing.

Preparing a meeting from an invitation sent to our own mailbox, which carries the organiser's address, the meeting title and the guest list: legitimate interest (Art. 6(1)(f)), kept proportionate by processing only what is needed to recognise and prepare that meeting.

Understanding which channels bring us users: legitimate interest (Art. 6(1)(f)). Commercial email: consent (Art. 6(1)(a)), asked only at sign-up and withdrawable at any time.

Keeping accounting records and answering lawful requests: legal obligation (Art. 6(1)(c)).

The database, authentication and documents are hosted on Supabase in the EU (Frankfurt). Recordings and screenshots are stored on Cloudflare R2 in a bucket created with EU jurisdiction. The recording witness runs in Amsterdam. Error reports are delivered to our monitoring provider's EU region.

Transcription does not leave that perimeter: it runs on our own infrastructure in the European Union, and the meeting audio is sent to no third party. Two transfers do leave it and we name them plainly. Stripe processes payments. Google (Gemini) receives the complete transcript, never the audio, to draft the automatic summary on the plans where that feature is offered; DeepSeek, outside the European Union, is used only as an emergency fallback for that same draft when Google does not respond, and a summary produced that way says so. These transfers are covered by the mechanisms those providers make available to their European customers; the written agreements formalising them are being completed, and this page will name them once they are signed.

You have the right of access, rectification, erasure, restriction, portability, and the right to object to processing based on legitimate interest. Where processing rests on consent, you can withdraw it at any time without affecting what was lawful beforehand.

Access and portability are self-service: Settings → Privacy builds a ZIP archive of your account data and emails you a download link, which stays valid for 7 days. You can request one export every 24 hours. Deletion of your account is also self-service, from the same page.

For anything else, including a request from someone who signed an agreement but has no account with us, write to hub@witup.ai. We answer within one month, and we say what we did and why, either way.

A sealed evidence package cannot be edited after its hash has been anchored, because editing it would destroy the proof it exists to provide. The name, email address, IP address and user agent of each signatory, and the transcript and event log of a protected meeting, are inside that package. They cannot be rectified or erased from it. A correction produces a new certificate in a documented revision chain; it never rewrites the old one.

Certificates already issued, and the signatory records behind them, therefore survive the deletion of the account that created them. This is deliberate: a certificate is evidence belonging to every bound party, and the counterparties keep their access to it.

What can always be done, on request and irreversibly, is the destruction of the stored recording of a protected meeting. The certificate stays valid and its hash remains as evidence that the recording existed as certified. The periodic screenshots and the transcript remain part of the sealed package.

If you think we have handled your data badly, tell us first at hub@witup.ai: we would rather fix it than be told about it by a regulator. You also have the right to lodge a complaint with the data protection supervisory authority of the country where you live or work, or with the supervisory authority competent for WitUp Ltd.