Compliance Details
Last updated: · Reviewed quarterly
GDPR Compliance: Be More Swan acts in two roles under UK GDPR / EU GDPR, as most business software does. For the business data you put into your workspace — your content, your contacts, and the data we read from the accounts you connect — we are a Data Processor, handling it on your instructions and for no other purpose. For your own account, login and billing data, and for running and securing the platform itself, we are a Data Controller, registered with the Information Commissioner's Office under number ZC272072. A Data Processing Agreement covering the processor role is presented to you in-product when you set up your organisation, and your acceptance is recorded; you can read it here at any time. If you need a countersigned copy for your own records, use the request form below. Our full Privacy Policy is available at /privacy.html. For erasure requests, please email hello@bemoreswan.com.
Data Residency
Your primary workspace data is stored in the United Kingdom — our
managed PostgreSQL database and our serverless functions are in London (eu-west-2), video rendering runs in AWS London,
and Netlify serves the pages themselves from its global edge network. Uploaded and generated media is held in
Cloudflare R2 object storage, which is globally distributed rather than pinned to a single region.
Being straight with you: some processing does happen in the United States, because the AI model
providers, our payment processor and our transactional email provider are US-based. Every one of those transfers
runs under the safeguards UK GDPR Chapter V requires — the UK International Data Transfer Agreement or the UK
Addendum to the EU Standard Contractual Clauses, or the UK Extension to the Data Privacy Framework in Stripe's case — supported by a documented Transfer Impact Assessment and minimisation of the
data sent to model APIs. The table below names each provider and where it sits.
Sub-Processors
Be More Swan uses the following third-party sub-processors to deliver its services. Each is assessed for UK GDPR compliance before we adopt it, and we rely on the provider's data processing terms for every transfer of personal data. Where a row is marked "copy on request", email us and we will send the current agreement.
| Sub-Processor | Purpose | Location | DPA / Security |
|---|---|---|---|
| Anthropic | AI language model inference — the primary model behind your assistants' drafting, chat and review | US | anthropic.com/legal/privacy |
| OpenAI | Content moderation screening and product tour narration | US | openai.com/enterprise-privacy |
| Voyage AI | Embedding of knowledge-base content so assistants can search it | US | Copy on request |
| fal.ai | AI image and video generation from your prompts | US | Copy on request |
| Stability AI | AI music generation from a text description of the track | UK / US | Copy on request |
| Neon | Managed PostgreSQL — where your workspace data is stored | UK (London) | Copy on request |
| Cloudflare R2 | Object storage — uploaded files and generated media | Global (Cloudflare network) | cloudflare.com/trust-hub/gdpr |
| Netlify | Hosting, serverless functions, scheduled jobs and CDN | UK (London) for functions; global edge network; US company | netlify.com/gdpr-ccpa |
| Amazon Web Services | Lambda video rendering for post and Short overlays | UK (London) | aws.amazon.com/compliance/gdpr-center |
| Stripe | Payment processing & billing | UK / US | stripe.com/gb/privacy |
| Resend | Transactional and notification email delivery | US | resend.com/legal/privacy-policy |
| Twilio SendGrid | Inbound email parsing — turns replies sent to us into workspace, support and CRM records | US | twilio.com/legal/privacy |
| Serper | Web search for the lead discovery runs you start | US | Copy on request |
| Pexels | Stock photo and video search — receives search terms, not your workspace data | Germany (EU) | pexels.com/privacy-policy |
Changes to this list. We email workspace owners at least 14 days before adding or replacing a sub-processor that handles your personal data, and you can object — see clause 5 of our Data Processing Agreement. Last updated 12 October 2026.
Platforms you connect are not on this list. When you connect an account — Google (Gmail, Search Console, Drive, Calendar), Microsoft Outlook, Canva, your social media accounts, your blog or your CRM — and tell an assistant to use it, we send data to that platform on your instructions. It acts under your own agreement with it, not as our sub-processor.
Encryption Standards
- ✓In transit: All data is encrypted in transit using TLS 1.3. Older cipher suites are disabled.
- ✓At rest: All database storage is encrypted at rest using AES-256 via the managed database provider's native encryption.
- ✓OAuth credentials & API keys: Stored with AES-256-GCM application-layer encryption. Plaintext credentials are never logged or returned to clients.
Security Testing
We have not yet commissioned an independent penetration test. When we do, we will publish the date here and share a summary with customers on request.
Until then, every change must pass our automated test suite before it reaches production, including tests that check one workspace cannot read another's records or files. To report a security concern, email hello@bemoreswan.com with the subject "Security".
Data Retention
- ✓Active accounts: Data is retained for the duration of your subscription.
- ✓After account deletion: Personal data is permanently deleted within 30 days of account closure. An anonymised erasure record is retained for compliance purposes.
- ✓Archived assistants: Kept for 14 days so you can reinstate them, then permanently deleted with their associated data.
- ✓Rejected and abandoned content: Rejected posts, unused generated media and incomplete setups are automatically cleared after 30 days.
- ✓Integration API call logs: Retained for 90 days, then automatically purged.
- ✓Audit records: Audit logs, DPA acceptances and erasure records are append-only and immutable — the database revokes UPDATE and DELETE on them and a trigger blocks any attempt, so they cannot be altered or removed by anyone, including us. This is deliberate: they are the evidence that the other rules above were followed.
Request a Data Processing Agreement
Enterprise customers and partners may request a signed DPA for their records. Complete the form below and we'll respond within 2 business days.
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