Processing is limited to operating the live-translation service: relaying and translating event audio in real time, optional transcript archiving, operator account management, and usage metering. The Controller's documented instructions are given through the service's settings; the Processor processes no personal data for its own purposes beyond security and billing records.
Data subjects: speakers at the Controller's events; the Controller's operators and volunteers. Data: live speech audio (transient), caption text (only when archiving is enabled, which is off by default), operator account names, sender-device names, usage records. Speech at religious events may reveal special-category data (Art. 9); the Controller is responsible for the lawful basis of capturing and translating its event audio.
TLS on all connections; per-organization isolation (separate service instances and data directories); per-device revocable sender credentials; operator authentication with hashed passwords; audit logging of control actions; EU-only hosting; nightly backups; access limited to the Processor.
Authorized: Google (Gemini API, paid tier; no use of Controller data for model training per Google's paid-services terms), Hetzner Online GmbH (hosting, DE), Stripe (payments). Changes are announced 14 days in advance to the contact e-mail on file; the Controller may object on reasonable data-protection grounds.
The Processor assists with data-subject requests and DPIAs to the extent the service holds relevant data; notifies the Controller of personal data breaches without undue delay; and on termination deletes the organization's instance data (transcripts, accounts, devices) except billing records retained under accounting law. Usage ledgers contain no audience personal data.
On request, the Processor provides a written description of measures and relevant logs; on-site audits are limited to once per year, at the Controller's cost, with 30 days' notice.
Draft note: working version for pilot organizations; legal review scheduled before general availability. Signed copies on request.