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Data Processing Agreement

Last Updated: June 25, 2026

This Data Processing Agreement (“DPA”) describes how Rogo Technologies, Inc. (“Arvo”) processes Personal Data in connection with its software platform and related services (the “Services”).

This DPA is intended to provide transparency regarding Arvo’s data processing practices and reflects the requirements of Article 28 of the General Data Protection Regulation (“GDPR”).

  1. Roles of the Parties

For purposes of GDPR:

Arvo acts as a Data Processor
Customers using the Services act as Data Controllers

Arvo processes Personal Data solely for the purpose of providing the Services and in accordance with the instructions of its customers.

  1. Scope and Nature of Processing

2.1 Nature of Processing

Arvo processes limited Personal Data as necessary to operate, secure, and improve its enterprise software, including:

  • Authentication

  • Product functionality

  • Security and fraud prevention

  • Aggregated usage analytics

  • Server routing and system administration

  • Optional cloud storage, synchronization, backup, or administrative audit functionality

Where cloud storage or synchronization features are enabled, meeting content may be hosted within Arvo’s secure cloud infrastructure.

2.2 Categories of Data Subjects

  • Employees, contractors, or authorized users of customer organizations

  • Business contacts interacting with Arvo for sales or support purposes

2.3 Categories of Personal Data

Arvo processes only limited Personal Data, including:

  • Pseudonymous technical identifiers (e.g., machine or device IDs and IP addresses)

  • Authentication identifiers (user name, email address, license key)

  • Basic usage and performance metadata

  • Business contact details (such as name, business email, company, and role), where applicable

  • Meeting content submitted to the Services, which may include names or other Personal Data contained within notes or transcripts

Arvo does not intentionally process special categories of personal data.

  1. Purpose of Processing

Arvo processes Personal Data solely for the following purposes:

  • Providing and maintaining the Services

  • Enforcing authentication and preventing misuse

  • Ensuring platform security and reliability

  • Producing aggregated, non-content-based usage analytics

  • Supporting customer communications and support

Arvo does not process Personal Data for advertising, behavioral profiling, or consumer marketing.

  1. Arvo Obligations

Arvo commits to:

  • Processing Personal Data only as necessary to provide the Services

  • Ensuring personnel are subject to appropriate confidentiality obligations

  • Implementing appropriate technical and organizational security measures

  • Assisting customers, where reasonably possible, with data protection obligations

  • Notifying customers without undue delay of any Personal Data breach

  1. Data Security Measures

Arvo implements appropriate technical and organizational measures, including:

  • Encryption in transit and at rest (where applicable)

  • Access controls and least-privilege permissions

  • Secure license validation mechanisms

  • Internal security policies and reviews

  • Vendor risk management and contractual safeguards

  1. Sub-Processors

Arvo may engage trusted third-party service providers (“Sub-processors”) to support the operation of the Services.

Arvo ensures that:

  • Sub-processors are bound by written data protection obligations

  • Sub-processors provide appropriate security safeguards

  • Arvo remains responsible for Sub-processor compliance

  • A current list of Sub-processors is made available separately.

  1. International Data Transfers

Arvo may process limited Personal Data outside the European Economic Area (“EEA”), including in the United States.

Where required by law, such transfers are safeguarded through appropriate mechanisms, including:

  • Standard Contractual Clauses (SCCs)

  • Contractual, technical, and organizational security measures

  • Data minimization and pseudonymization

  1. Data Subject Rights

Taking into account the nature of processing, Arvo supports customers in responding to data subject requests where reasonably feasible.

Because Arvo primarily processes pseudonymous technical identifiers, Arvo may not be able to identify a data subject without additional information. Where identification is not possible, certain data subject rights may not apply.

  1. Data Retention and Deletion

  • Personal Data is retained only for as long as necessary to operate the Services or meet legal obligations

  • Meeting content stored in Arvo’s cloud environment (where enabled) is retained in accordance with the customer’s configuration and retention settings

  • Upon termination of service usage, Personal Data is deleted or anonymized in accordance with Arvo’s retention practices, unless retention is legally required

  1. Updates to This DPA

Arvo may update this DPA from time to time to reflect legal or operational changes. Updates will be posted on this page.

  1. Contact
    For questions regarding this DPA or data processing practices:
    Arvo AI, Inc.
    Email: [email protected]