Probook Agent Annex — Data Processing Agreement
Last updated: October 2026
This annex supplements the Data Processing Agreement (useprobook.com/legal/dpa) for the Probook Agent service (phone assistant and e-mail triage). Where they differ, this annex prevails for Probook Agent. UseProBook acts as Processor under Article 28 GDPR; the Professional is the Controller.
1. Subject
Answering calls and, depending on the plan, e-mails addressed to the Professional: understanding the request, answering the questions set out in their script, booking or noting an appointment or message, and passing each request on to the Professional.
2. Data and data subjects
- Data subjects: people who call or write to the Professional.
- Data: voice and call recording, transcript, caller's phone number, name, contact details and content of the request, automatically produced summary and record, appointments booked.
- Sensitive data: the assistant does not ask for it. If the Professional works in healthcare, callers may mention it; the Professional tells UseProBook before activation and adapts the script to keep such information to the strict minimum.
3. Informing callers
At the start of every call the assistant says it is an artificial intelligence and that the call is recorded (EU AI Act and GDPR). Before hanging up, it reminds the caller they can ask for the recording to be deleted. The Professional also informs their customers in their own privacy policy.
4. Retention
- Recordings and transcripts: deleted automatically after 90 days, and immediately if the caller asks during the call.
- Requests and messages passed to the Professional: kept in their dashboard while the account is active, then as set out in section 9 of the Data Processing Agreement.
5. Sub-processors specific to Probook Agent
In addition to those in the Data Processing Agreement, the Professional authorises:
- ElevenLabs (Eleven Labs Inc., United States) — speech recognition and synthesis, running the conversation, storing recordings and transcripts (servers in the United States);
- Google (Google Cloud) — language model that generates the assistant's replies, used by ElevenLabs;
- Telephone carrier — routing calls to the assistant; its name is given to the Professional in writing before the line is activated.
The 30-day notice rule and right to object in the Data Processing Agreement also apply to this list.
6. Transfers outside the EU
Recordings and transcripts are processed in the United States. These transfers rely on the European Commission's standard contractual clauses in each provider's data processing agreement and, where certified, on the EU-US Data Privacy Framework. Probook's database (requests, appointments, accounts) stays in the European Union.
7. Security
Connections between our systems and the providers' systems are encrypted (TLS). Access to recordings is limited to the Professional and to the people at UseProBook who need it to run the service. The part of the call that travels over the public telephone network depends on the carriers and is not end-to-end encrypted.
8. Contact
For any question or deletion request, write to app@useprobook.com.