Legal · Product
Morgan Privacy Notice
Last updated 27 October 2026
Pre-launch draft, finalised before Morgan is generally availableThis notice explains how Morgan, the product built by Emotional Computing Ltd, handles your personal data. It is separate from our website Privacy Policy, which covers this site only. Because Morgan is a companion you talk to, it necessarily works with more personal information than a website, so we set out clearly what that is, where it lives, and the control you keep over it.
Who we are
Emotional Computing Ltd, Company No. 17082850, registered in the United Kingdom, is the data controller for personal data processed by Morgan. Registered with the UK Information Commissioner’s Office (ICO), reference ZC198257. Contact: privacy@emotionalcomputing.co.uk.
What Morgan processes
- Your conversations: what you say to Morgan, by text or voice, and Morgan’s responses.
- Voice audio: where you speak to Morgan, to understand you and to reply in a natural voice.
- Memory: the things Morgan remembers to be a consistent companion, such as people, preferences, context, and the meaning of past conversations.
- Settings & preferences: such as your chosen voice and how you like Morgan to behave.
- Technical & usage data: information needed to run the service reliably and securely.
Why we use it
We use this information solely to provide Morgan to you, to understand you, remember context, respond, and keep the service reliable and safe. We do not sell your data, we do not profile you for advertising, and we do not use your conversations to train any AI model, ours or anyone else’s. Our lawful bases are your consent and performance of our agreement with you.
Where your data is held
Morgan runs on Microsoft Azure. Actions Morgan takes on your computer run on your computer. Your memory is stored in the United Kingdom (UK West). To reply to you, Morgan sends the parts of your memory that matter to the conversation, along with your message, to an AI model. That processing may take place outside the UK. Microsoft and our other AI providers may keep a copy of a request for a limited period to check for misuse. Where data is processed outside the UK, the transfer is covered by an approved safeguard, described under International transfers below.
Your sign-in details (the email address you register with and a protected form of your password) are held by Microsoft Entra External ID, Microsoft’s sign-in service. Microsoft stores them in its datacentres in Europe (the EU and EEA), not in the United Kingdom.
As on-device technology matures (see Morgan OS), more of this will run locally on your own hardware, keeping even more of your data on your device.
Who processes it on our behalf
We rely on a small number of trusted sub-processors, each bound by data-protection terms that forbid using your data to train their AI models:
- Microsoft Azure: hosting, storage, and much of Morgan’s AI reasoning.
- Microsoft Entra External ID: your sign-in account, stored in Europe.
- Specialist AI providers: for deeper reasoning and for image or video generation, each under paid or enterprise terms that prohibit training on your data.
A current, full list of our sub-processors is available on request, just email privacy@emotionalcomputing.co.uk.
Your control
You can review and delete what Morgan remembers, and ask us to delete your data entirely. We keep your data only while you use Morgan and for up to 18 months after your last activity, or sooner if you ask us to delete it, after which we remove it.
Security
Your data is encrypted in transit and at rest. Actions Morgan takes on your behalf pass through policy checks and are recorded in a tamper-evident log. By default, anything that reaches the outside world is confirmed with you first.
Older and vulnerable users
Morgan is intended to support connection and wellbeing, including for older adults. It is not a medical device and is not a substitute for professional, medical, or emergency care. Where Morgan is set up for someone who cannot give their own consent, it should be done by a person with the proper authority to do so on their behalf, and with their best interests in mind. We take safeguarding seriously and welcome contact from carers and families at hello@emotionalcomputing.co.uk.
Children
Morgan is for adults. You must be 18 or over to hold a Morgan subscription, and Morgan is not directed at or intended for children. If you believe we hold a child’s personal data, email privacy@emotionalcomputing.co.uk and we will delete it.
International transfers
Some of the providers described above process data outside the United Kingdom, including the parts of your memory that are sent with each message. Where they do, the transfer is protected by an approved safeguard under UK data protection law: the UK’s adequacy regulations, the UK-US Data Bridge, the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses. Your sign-in details are held in Europe, and the UK’s adequacy regulations cover transfers to the European Economic Area.
Your rights
Under UK GDPR (and EU GDPR where applicable) you have the right to access, correct, delete, or receive a copy of your data, to withdraw consent, and to object to or restrict processing. To exercise these, email privacy@emotionalcomputing.co.uk. You can also complain to the UK Information Commissioner’s Office (ico.org.uk).
Changes
Morgan is evolving, and we will finalise and update this notice as the product develops. The current version will always be available here.
Questions about how Morgan handles your data? Email privacy@emotionalcomputing.co.uk.