the agreement
Data processing addendum
Version: 13 October 2026
This Data Processing Addendum (DPA) governs how Goldfish AI Inc. processes personal data on Customer's behalf when providing the Service. It applies once it is incorporated into the Agreement or otherwise accepted by both parties.
Cover Page
| Term | Detail |
|---|---|
| Provider | Goldfish AI Inc., 131 Continental Dr, Suite 305, Newark, Delaware 19713, United States of America |
| Customer | The organisation identified as Customer in the Agreement. An individual who accepts for an organisation confirms they have authority to bind it. |
| Agreement | The Goldfish Terms of Service, or a separate written agreement or order form for Customer's use of the Service that incorporates this DPA. |
Acceptance and effective date. This DPA takes effect when the parties accept an Agreement that incorporates it, or otherwise expressly accept it electronically or in writing. Electronic acceptance of an Agreement that incorporates this DPA constitutes acceptance of this Cover Page and the DPA Standard Terms, and no separate signature is required. Viewing this page does not constitute acceptance.
DPA Standard Terms
This Cover Page, with its Annexes, incorporates the Common Paper DPA Standard Terms Version 1.1. Capitalised terms not defined here have the meaning given in the DPA Standard Terms or the Agreement. A variable this Cover Page leaves out means "none" or "not applicable".
This Cover Page prevails over the DPA Standard Terms where they conflict. The EEA SCCs and the UK Addendum prevail over both, as Section 9.1 of the DPA Standard Terms provides.
Scope and roles
- Provider as Processor. Provider processes Customer Personal Data as Customer's Processor, or as Subprocessor where Customer is itself a Processor. Customer Personal Data means personal data contained in:
- Request Content: the selected text context and, for dictation, the voice input that the Goldfish application sends for AI processing; and
- Account Data: the identity, authentication, session and organisation-membership records of Customer's authorised users.
- Data that stays on the device. The memory the Goldfish application builds, including captured text, summaries and preferences, is stored only on the authorised user's device. Provider does not receive, store or have access to it, so Provider does not process it under this DPA.
- Provider as Controller. Provider is an independent Controller, under its Privacy Policy, of billing and business-contact data, of event-only product telemetry, and of data it must process to secure the Service or meet its legal obligations. That telemetry does not include Request Content or the content of on-device memory.
Key Terms
| Term | Detail |
|---|---|
| Provider Security Contact | Kaspian Jakobsson, CTO, kaspian@goldfish.sh |
| Security Policy | Provider will maintain the technical and organisational measures in Annex II. Provider may update them, provided the overall level of protection is not reduced. |
| Security Incident notice | Without undue delay, and no later than 72 hours after Provider becomes aware, as Section 4 of the DPA Standard Terms provides. Notices go to the Customer contact named in the Agreement. |
| Subprocessor changes | At least 10 business days' written notice before a new or replacement Subprocessor starts. Customer has 30 days to object, as Section 2.6 of the DPA Standard Terms provides. |
| Deletion | Provider will delete Account Data within 30 days of Customer's written instruction or of the Agreement ending, whichever comes first. Request Content is not stored once the response has been returned. Backup copies expire on the hosting provider's normal backup cycle. |
Security Reports
Section 5.2 of the DPA Standard Terms is replaced with the following.
On Customer's written request, Provider will give Customer, in confidence, any current independent security audit report on the Service that Provider holds and is permitted to disclose. Provider does not represent that it holds a certification or has completed an independent security audit. Nothing in this section limits the information, cooperation or audit rights that Applicable Data Protection Laws, the EEA SCCs or the UK Addendum give Customer.
Approved Subprocessors
Customer approves the Subprocessors below for the Customer Personal Data and tasks listed.
| Subprocessor | Country of location | Anticipated processing task |
|---|---|---|
| Microsoft Corporation (Azure OpenAI) | United States. Processing takes place in Microsoft's EU data zone, through Provider's Azure OpenAI resource in Sweden Central | Language-model inference on Request Content and transcription of dictation audio. Processed under Microsoft's modified abuse monitoring: prompts, completions and audio are not stored after the response and are not used to train models. |
| Cloudflare, Inc. | United States, with a global edge network | API gateway for the Service: authenticates, rate-limits and routes requests. Request Content passes through in transit and is not stored or logged. Logs hold request metadata only, such as user ID, model and status. |
| Specific AI Inc. | United States | Hosting of the sign-in service and the account database. Processes Account Data: name, email, password hash or Google sign-in tokens, and session records. |
| PostHog Inc. | United States | Support tickets, error reports, and diagnostic bundles an authorised user chooses to send, which can include recent AI request traces. |
| Plus Five Five, Inc. (Resend) | United States | Delivery of transactional and onboarding email. Processes email address and name. |
| Google LLC | United States | Optional Google sign-in. Processes email address and profile at sign-in. |
Provider also uses PostHog Inc. for product telemetry and Stripe, LLC (United States) for subscription billing. Provider is the Controller of that data, as the Cover Page states, so those uses are outside the Subprocessor approval above.
Restricted Transfers
Section 3 of the DPA Standard Terms sets out the transfer safeguards. They apply as follows.
| Transfer | Mechanism |
|---|---|
| From the United Kingdom | The UK Addendum, deemed signed under Section 3.3 of the DPA Standard Terms. It is appended to the EEA SCCs as completed under Section 3.2. |
| From the EEA | The EEA SCCs, deemed signed under Section 3.2 of the DPA Standard Terms. |
| From Switzerland | The EEA SCCs, adapted as Section 3.4 of the DPA Standard Terms provides. |
| SCC module | Module Two where Customer is a Controller. Module Three where Customer is a Processor. |
| Governing Member State for EEA transfers | Ireland |
Service Provider Relationship
Where the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (CCPA), applies, Provider acts as Customer's service provider. Provider receives Customer Personal Data only to provide the Service described in Annex I B, which is a limited and specified business purpose.
Provider will not sell or share Customer Personal Data. Provider will not retain, use or disclose it except as needed to provide the Service, as the Agreement states, or as Applicable Data Protection Laws permit. Provider certifies that it understands these restrictions and will tell Customer if it can no longer meet its CCPA obligations.
Annex I A: List of Parties
| Data exporter | Data importer | |
|---|---|---|
| Name | Customer, as identified in the Agreement | Goldfish AI Inc. |
| Address | Customer's address in the Agreement or its account records | 131 Continental Dr, Suite 305, Newark, Delaware 19713, United States of America |
| Contact | Customer's contact in the Agreement or its account records | Kaspian Jakobsson, CTO, kaspian@goldfish.sh |
| Role | Controller, or Processor where Customer processes for another Controller | Processor, or Subprocessor where Customer is a Processor |
| Activities | See Annex I B | See Annex I B |
| Signature | Customer's acceptance of this Cover Page | Provider's acceptance of this Cover Page |
Annex I B: Description of Transfer and Processing
Service. Goldfish is a desktop assistant for macOS and Windows. It reads text from the active application through the operating system's accessibility APIs and builds a memory of the user's work on the user's device. It uses that memory to draft, rewrite, recall, summarise and dictate. AI generation runs on Provider's Azure OpenAI deployment, reached through a gateway Provider operates on Cloudflare.
| Item | Detail |
|---|---|
| Categories of Data Subjects | Customer's employees, contractors and other authorised users. Other individuals whose personal data appears in text an authorised user has on screen and that forms part of Request Content, such as colleagues, clients and correspondents. |
| Categories of Personal Data: Account Data | Name, email address, password hash or Google sign-in identifier, session records including IP address and user agent, plan and usage totals. |
| Categories of Personal Data: Request Content | The user's message, a short identity summary of the user, context retrieved from on-device memory for that request, and voice audio for dictation. This free text can include names, contact details and message content relating to other individuals. |
| Categories of Personal Data: request metadata | User ID, model, status, timestamps and rate-limit events. |
| Special Category Data | The Service is not designed for Special Category Data and Customer does not intend to submit it. Request Content is drawn from the user's work, so it may contain such data incidentally. |
| Special Category Data safeguards | On-device masking before storage, default and user-set capture exclusions, zero data retention for AI processing, and the measures in Annex II. |
| Frequency of Transfer | Continuous: whenever an authorised user invokes an AI feature, and when background features organise on-device memory. |
| Nature of Processing | Receiving, transmitting, transient computation to generate a response, storage of Account Data, authentication, and deletion. |
| Purpose of Processing | To provide the Service to Customer's authorised users: generate drafts, answers, summaries and transcriptions, authenticate users, send service email, and provide support. |
| Duration of Processing | Request Content: for the length of each request. Account Data: for the term of the Agreement and the deletion period in the Key Terms. Diagnostic bundles: until the support matter is closed. |
Annex I C: Competent Supervisory Authority
The supervisory authority is that of the data exporter, determined under Clause 13 of the EEA SCCs. For transfers under the UK Addendum it is the UK Information Commissioner.
Annex II: Technical and Organisational Security Measures
Provider maintains the measures below for Customer Personal Data.
| Area | Measure |
|---|---|
| Data minimisation | The memory the application builds stays on the user's device, with no cloud copy and no sync. An AI request carries only the user's message, a short identity summary and the context retrieved for that request. |
| Capture controls | The application never reads password fields. By default it skips password managers, banking sites, sign-in and checkout pages, and private browser windows. Users can pause capture and exclude any app or domain. |
| Masking | Before captured text is stored on the device, the application masks payment card numbers and security codes, IBANs, US Social Security numbers, and passwords, API keys, tokens and private keys. Masking is pattern-based and does not remove names or contact details. |
| Encryption in transit | All connections from the application use TLS 1.2 or 1.3 with certificate validation that cannot be disabled. Dictation audio uses the same stack over secure WebSocket. |
| Encryption at rest | The account database is encrypted at rest by the hosting provider. Passwords are stored as bcrypt hashes and the token-signing key is stored encrypted with AES-256-GCM. On the device, data is protected by owner-only file permissions and the device's full-disk encryption. |
| AI processing | Requests go to Provider's own Azure OpenAI deployment under Microsoft's modified abuse monitoring. Microsoft does not store prompts, completions or audio after the response, does not review them, and does not use them to train models. The gateway does not log or store request or response bodies. |
| No training | Provider does not use Customer Personal Data to train AI models. |
| Authentication | Sign-in uses OAuth 2.0 with PKCE or email and password with verified email. The gateway accepts only short-lived signed tokens, valid for 15 minutes. Sign-up, password reset and sign-in routes are rate-limited. |
| Access control | Access to Provider's production systems is limited to named personnel with individual accounts and two-factor authentication. Secrets are held in the platforms' secret stores. Personnel have no route to the memory on a user's device. |
| Personnel | Personnel who can access Customer Personal Data are bound by confidentiality obligations. |
| Change management | All changes go through version control and automated build, lint and test gates. Dependencies are pinned and scanned for known vulnerabilities with Dependabot. Releases are code-signed and notarised, and the application installs only updates that carry a valid signature. |
| Logging and monitoring | Gateway logs record request metadata, rate-limit and block events. Application errors are collected in error tracking. Neither contains captured content. |
| Incident response | Provider has a named incident owner who triages, contains and remediates Security Incidents, and Provider notifies Customer as the Key Terms state. |
| Resilience | The gateway runs on a global edge network with fallback AI deployments. The account database is backed up by the hosting provider. Capture, search and on-device memory keep working without network access. |
| Subprocessors | Each Subprocessor is bound by a written data processing agreement. |
The DPA Standard Terms are the Common Paper DPA Standard Terms Version 1.1, free to use under CC BY 4.0. Questions about this DPA: kaspian@goldfish.sh.