For data protection officers

Last updated 11 October 2026

This page is for whoever has to approve Roundnote at work: a data protection officer, a privacy lead or IT. It sets out what Roundnote processes, where, on whose behalf and for how long. Roundnote is made by I-DEV B.V. in the Netherlands (“we”). The privacy policy covers the same ground for the people who use it; this page goes into what a review needs. It describes how the app works. It isn't legal advice.

In short

• Roundnote processes meetings on the Mac of the person who records them. We don't receive recordings, transcripts, summaries, voice profiles or anything else from them: there's no Roundnote server and no account.
• Your organisation is the controller for what its people record. We're not a processor, so there's no processor agreement to sign with Roundnote.
• A voice profile, used to recognise someone across meetings, is biometric data under GDPR Article 9. Roundnote stores one only after the user confirms the person explicitly agreed, keeps it on the Mac and deletes it when asked.
• Meeting data leaves the Mac only when the user sets it up or asks: an AI service your organisation chooses, an assistant such as Claude or ChatGPT, an email, a shared file. Each meeting lists where it went, and when.

Contents

1. What is processed where
2. Who is controller and processor
3. Voice profiles and Article 9
4. AI services you choose
5. Claude, ChatGPT and the MCP server
6. What left this Mac, per meeting
7. Retention and deletion
8. Security
9. Why there's no processor agreement
10. Questions

1. What is processed where

Roundnote is a Mac app, with companion apps for iPhone, iPad and Apple Watch that record and send the recordings to the Mac; they don't transcribe. Everything is processed and kept on the Mac unless the last column says otherwise.

The app's folder is ~/Library/Containers/eu.roundnote; the folder it shares with its MCP server is in ~/Library/Group Containers, its name ending in eu.roundnote. The key for an AI service and any calendar link are kept in the Mac's Keychain. The live text shown while recording is a preview and isn't stored, nor is its translation; the names the user gives voices there are kept with the meeting.

2. Who is controller and processor

When someone in your organisation records a meeting with Roundnote for work, your organisation decides why and how the data is processed, so it's the controller (Article 4(7)), and the person recording acts on its behalf. I-DEV B.V., which makes Roundnote, isn't a processor (Article 4(8) and 28): Roundnote is software that runs on your Mac, and we never receive, see or store what it processes. It works like a word processor in that respect.

Others can process meeting data, each only when someone in your organisation sets it up or asks:

• An AI service for transcription or summaries, under your own account: OpenAI, Azure OpenAI, Groq or any OpenAI-compatible service. That provider is your processor; its agreement and where it processes are between your organisation and it. A model server on your own network keeps it in house. See AI services you choose.
• Anthropic or OpenAI, when a user connects Claude or ChatGPT, or shares a meeting with them. See Claude, ChatGPT and the MCP server.
• Mistral AI, Google or another provider, when a user switches on Mistral Vibe, Gemini or an assistant of their own in Settings › Assistants and shares a meeting with it.
• Your email provider, when a user emails a meeting from Mail or Outlook.
• Apple: summaries by Apple Intelligence are written on the Mac, and Apple's translation translates on the Mac, once macOS has downloaded the languages. A later version may offer Apple's Private Cloud Compute for long meetings, where Apple processes the transcript on its servers without keeping it; it will be a choice, and each meeting will list it. Apple also handles the purchase, and sends crash reports to us only if the user shares analytics with developers in macOS; they hold no meeting data.

Roundnote itself makes no transfers outside the EU. A service your organisation chooses may; choose with that in mind.

3. Voice profiles and Article 9

Recognising a person by their voice in later meetings uses biometric data to identify them: a special category under Article 9(1). The lawful basis Roundnote is built around is that person's explicit consent (Article 9(2)(a)), collected by the user, and the app is made so that a voice profile can't exist without it:

• When the user names a new voice, Roundnote asks whether that person explicitly agreed to have their voice remembered. Only “Agreed: Remember Voice”, with the person's name in front, stores a voice profile, with the date of the answer. “Name for This Meeting Only”, the default button, stores none.
• Only people who agreed, and the user themselves (“This is me”), are recognised or learned from. People named before Roundnote asked are asked about once; until the user answers, their profiles are kept but not used.
• Consent can be withdrawn at any time: Forget Voice deletes a person's voice profile and its short sample recordings and keeps the name; Delete removes the person; Forget All Voices deletes every profile.
• Remembering voices can be switched off for the whole app, for a category (an HR category, say) or for one meeting. Those meetings keep no voice profiles at all, and what was taken from them earlier is forgotten.
• While recording, the live text tells voices apart (Speaker 1, Speaker 2…) and compares them only with people who agreed, to show their names; it stores no voice data. A name the user gives a voice there is used for that meeting, and for a person who hasn't agreed, Roundnote asks “Remember Jan's voice?”, with the same answers, when the finished meeting first opens.
• Voice profiles never leave the Mac: not to an AI service, not to an assistant, not to us.

Within one meeting, Roundnote also compares voices to tell the speakers apart, and to see whether one of them is someone who agreed to be recognised. The fingerprints it uses for that stay in that meeting's file, so speakers can be split or merged later, and go when the meeting is deleted. They're never used to recognise that person in another meeting.

Asking is the user's part. Roundnote helps: the recording notice asks the user to tell the others; Copy Consent Line puts a ready-made line on the clipboard for the meeting chat or the invitation (“I'm transcribing this meeting on my Mac with Roundnote. Nothing is uploaded, and your voice is only remembered if you agree. Tell me if you'd rather not.”), which the user can change, and Roundnote puts it there by itself when it starts recording a call, unless switched off; and Settings › Privacy has a longer text to share, saying what's kept, why, where and for how long, which follows the app's settings. Roundnote doesn't announce itself in a call.

4. AI services you choose

Out of the box, Roundnote transcribes and summarises on the Mac, with models built into the app (Parakeet, Whisper, Apple Intelligence, Gemma 4), and no meeting data leaves it. An organisation can choose a service instead, in Settings › AI:

• Transcription sends the meeting's audio, in parts of up to ten minutes, with the word list as spelling hints.
• Summaries send the transcript with the speakers' names, the category's instructions and the word list, and the user's own notes and marked moments with what was said around each. The meeting's title, category and digest (topics, decisions and action items) are made by the same service.
• Translation, only when the user chooses Translate Summary › With the AI Service, sends the summary, to the service set up for summaries.
• Roundnote asks once for each server, saying what goes there, before any meeting goes to it, and sends nothing to a server that wasn't allowed, whatever set its address: Settings, an imported settings file or a configuration profile.
• Everything goes straight from the Mac to the address entered, over HTTPS (plain HTTP only to the same Mac or the local network), with your organisation's own key. The key stays in the Keychain and goes only to that address.
• Recognising voices never goes to a service.

Roundnote's settings are standard macOS preferences for eu.roundnote, so IT can preset them for everyone with a configuration profile, and Settings › General exports them as a file, without the key, for colleagues to import.

5. Claude, ChatGPT and the MCP server

Roundnote includes roundnote-mcp, a small sandboxed program inside the app. When a user adds Roundnote to the Claude desktop app, Claude Code or the ChatGPT desktop app (Settings › Assistants: Add to Claude… saves an extension the user installs in Claude; Add to ChatGPT… adds an entry to ~/.codex/config.toml, the settings file the user chooses, keeping the rest of it), that app starts roundnote-mcp on the same Mac to look things up. roundnote-mcp has no network access of its own, and works while Roundnote is closed.

• What the assistant can read: lists of meetings and people (titles, dates, names), summaries, decisions, action items, topics and the transcript, a page at a time, or the passages it searches for, from the search index on the Mac, read-only. Its 16 tools: find_meetings, search, get_meeting, list_people, get_person, list_tags, action_items and open_meeting to read and open; save_refined_summary, save_action_items, complete_action_item, save_translated_summary, save_decisions, save_title, save_tags and save_meeting_text to save.
• What it can't: voice profiles and recordings, and meetings or categories set to Hide from Assistants, which it can't save anything to either. Those meetings stay out of Spotlight and Siri too.
• What it can change: only what its saving tools allow, each shown as from Claude or ChatGPT: a refined summary, with Roundnote's own kept one click away; a translated summary, kept next to the original; action items, and marking them done, where an item of Roundnote's own for the same task then makes way; decisions, shown under the summary in place of the ones Roundnote found; tags, in place of Roundnote's; a new title, which replaces the meeting's as a rename would; and an extra section under its own heading, which goes into the user's downloads but never into an email, Send to Invited People or what goes to an assistant. It can't change transcripts, people's names or Roundnote's own summary.
• Where it goes: what the assistant reads becomes part of the chat, and is sent to Anthropic or OpenAI under the user's own account and their terms. For your organisation that's a use of that assistant like any other; decide whether you allow it.

A user can also share one meeting from its Share menu, with Copy for AI or an Ask item: Ask Claude and Ask ChatGPT are there unless switched off, Ask Mistral Vibe, Ask Gemini and an assistant of the user's own once switched on in Settings › Assistants. Each offers Your Own Question and the requests from the Requests window, which say what they send (the transcript, the summary, the action items or the user's notes) and what they ask the assistant to save back. Ask opens a new chat in the assistant's app or on its website with the text filled in when it fits in the link, or puts it on the clipboard; nothing is sent until the user presses Return. Once Claude or ChatGPT has used Roundnote's tools, only the request goes along and the assistant reads the meeting through roundnote-mcp, as above. Mistral Vibe and Gemini get what's shared by the clipboard, and neither can read or save through Roundnote. The user's own notes and marked moments go along when the request sends them; they never go into an email. Not connecting an assistant keeps meetings away from it altogether; hiding a meeting or category from assistants keeps it out of what they can look up, and leaves only sharing it by hand.

6. What left this Mac, per meeting

Each meeting keeps a short list of the times it left the Mac: when, where and how, never what. It shows in the meeting, and goes into the copies the user downloads and the transcripts folder; never into what's emailed or shared with others.

• Transcribed or summarised by an AI service, or its summary translated by one, with the service's address (and the language, for a translation).
• Summarised through Apple's Private Cloud Compute, once a version offers it.
• Read by Claude or ChatGPT through Roundnote, with what it looked up and when.
• An email opened to people, named, with their addresses, from Share › Email, Email with Outlook or Send to Invited People.
• Shared with an assistant from the Share menu or with Copy for AI: the assistant, how (a new chat in its app, its website or the clipboard), what went along (such as the summary, the action items and the user's notes) and the request it went with, by name; or only the request, when the assistant reads the meeting itself through Roundnote.

Spotlight and Roundnote's own search index stay on the Mac and aren't listed. The list records what Roundnote did: once an email is open or a meeting is on the clipboard, the user decides where it goes next, and Roundnote can't see that.

7. Retention and deletion

Everything stays on the Mac until it's deleted, and Roundnote keeps no copies elsewhere. A user, or IT through the settings, can:

• delete a meeting with its recording, or only the recording and keep the transcript;
• have recordings deleted after a number of days (Settings › Storage);
• have meetings deleted for good after a set time, for all meetings or per category (Settings › Privacy). Both are off until switched on;
• forget a person's voice, a person or all voices at once. A voice profile otherwise stays until then.

The search index is made from the meetings and follows them. Roundnote keeps a short list of recent warnings and errors for the diagnostics file, with titles, names and paths taken out (at most 64 KB), and a step log only while debug mode is on, without meeting text or names. What was sent to a service follows that service's retention.

Requests from the people recorded (access, erasure, objection) go to your organisation as the controller. On the Mac, People shows every meeting a person was named in, and a meeting can be downloaded or deleted, or the person's voice forgotten. We can't see or delete anything on your Macs.

8. Security

• The Mac app runs in the macOS App Sandbox with the hardened runtime, and is signed and distributed through the Mac App Store. It contains no analytics, advertising or tracking code; the built-in models and other parts are listed with their licences in Settings › General › Acknowledgements.
• At rest, meetings are protected as the Mac protects the user's files: use FileVault and a login password. Roundnote doesn't encrypt its own files. Its Touch ID lock keeps meetings out of view in the app, Spotlight, Siri and notifications.
• In transit: HTTPS to AI services. From iPhone to Mac, recordings are encrypted end to end (X25519 key agreement, ChaCha20-Poly1305) with a key made when the devices are paired; the Watch sends to the iPhone over Apple's own connection.
• Diagnostics reach us only when the user chooses Help › Send Diagnostics, sees the file and sends the email. The file holds nothing from meetings: no transcripts, summaries, titles or names.

9. Why there's no processor agreement

Article 28 applies to someone who processes personal data on your behalf. We don't: Roundnote has no server, no account and no analytics, and the app never sends meeting data to us. What we do receive, we receive as anyone would: visits to this website and support emails, with the diagnostics file if someone attaches it. The privacy policy covers those, with I-DEV B.V. as their controller.

For a data protection impact assessment (Article 35), the facts on this page are meant to be usable as they stand. If your procurement process asks for them in writing, email us and we'll confirm them.

10. Questions

Write to support@roundnote.eu. We answer in English or Dutch, usually within a few working days. When Roundnote starts handling data differently, we update this page and its date before that version is released.