Who we are
[Company legal name] (“we”) uses a cloud calling service to phone and text customers and prospects. We are the controller of the personal data described here. Contact: [privacy email], [postal address]. [If you have one: our data protection officer is … / our EU or UK representative is ….]
What we collect when we call or text you
- Contact details: your name, company, job title, phone numbers and email, from [you / your employer / public sources / list provider].
- Call records: the numbers involved, date, time, duration, whether the call was answered, and which of our staff handled it.
- Notes and outcomes our staff write about the conversation, and any follow-up we schedule.
- Call recordings and transcripts, only when recording is turned on. [Describe when: e.g. all calls / only when the agent starts it.] You are told at the start of the recording.
- Voicemails you leave us, and text messages exchanged with our numbers.
Why we use it, and our legal basis
- To respond to you and provide our services: [performance of a contract / steps at your request].
- To contact business prospects about our products: [legitimate interests, balanced against your right to object / consent where the law requires it].
- To record calls for [training, quality, dispute resolution]: [consent / legitimate interests], announced on the call.
- To honor opt-outs and keep do-not-call records: legal obligation.
Who processes it for us
Our calling software provider hosts call records for us. Calls, texts, recordings and transcripts are carried and stored by Twilio Inc. (United States) as our processor. [List hosting provider, CRM, email provider.] Where data leaves [the EEA / UK], we rely on [Standard Contractual Clauses / the EU–US Data Privacy Framework / …].
How long we keep it
- Recordings and transcripts: [90] days, then deleted automatically from our systems and from Twilio.
- Call records and notes: [period, or “while you are a customer and [N] years after”].
- Do-not-call entries: kept for as long as needed to keep honoring your request.
Your choices and rights
- Stop calls or texts: tell the person who calls you, reply STOP to any text, or email [privacy email]. We add your number to our do-not-call list, which blocks further calls and texts from our system.
- Object to recording: say so on the call and we will [stop the recording / continue without recording / offer another channel].
- Depending on where you live, you may have the right to access, correct, delete, restrict or port your data, to object to our use of it, and to withdraw consent. We answer within [30 days]. You can also complain to your data protection authority: [name and link].
- [California residents: categories collected, sold/shared = none, right to know/delete/correct, non-discrimination.]
Changes
We will post updates here and change the date above. [Material changes will also be notified by ….]