Effective Date: 09-8-2024

A. This Policy

Telefony.ai (“us”, “we”, or “our”) operates www.telefony.ai (hereinafter referred to as “Service”). This Privacy Policy governs your visit to www.telefony.ai and our associated web and mobile applications. It explains how we collect, safeguard, and disclose information resulting from your use of our Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined herein, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions. Our Terms and Conditions (“Terms”) govern all use of our Service and, together with this Privacy Policy, constitute your agreement with us (“Agreement”).

B. Definitions

SERVICE refers to the www.telefony.ai website and any associated web, mobile, or other applications operated by Telefony.ai.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and how any personal data are or are to be processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service, corresponding to the Data Subject

C. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

D. Types of Data Collected

- Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). This may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may interest you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

- Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through a mobile device.

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data.

- Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). This helps us provide features of our Service, improve, and customize our Service. You can enable or disable location services when you use our Service at any time via your device settings.

- Tracking Cookies Data

We use cookies and similar tracking technologies to track activity on our Service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies: We use Session Cookies to operate our Service.
• Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
• Security Cookies: We use Security Cookies for security purposes.
• Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

- Other Data

While using our Service, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, non-disclosure agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location, and other data.

E. Use of Data

Telefony.ai uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent, and address technical issues
• To fulfill any other purpose for which you provide it
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
• To provide you with notices about your account and/or subscription, including expiration and renewal notices, email instructions, etc.
• To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
• In any other way, we may describe when you provide the information
• For any other purpose with your consent

C. Data Retention

We will keep your Personal Data only as long as necessary to fulfill the objectives outlined in this Privacy Policy. Your Personal Data may also be retained to meet our legal obligations (such as compliance with applicable laws), manage disputes, and uphold our legal agreements and policies. Additionally, Usage Data will be retained for internal analytical purposes. This Usage Data is usually stored for a shorter duration unless used to enhance security or improve our service functionality, or unless legal obligations require us to retain it for longer periods.

D. Data Transfer

Your information, including Personal Data, may be transferred to — and stored on — servers located outside your specific jurisdiction (state, province, country, or other governmental area), where data protection laws may differ from those in your location. If you provide information while located outside the United States, please be aware that your data, including Personal Data, will be transferred to the United States for processing. By consenting to this Privacy Policy and submitting your information, you agree to this transfer. Telefony.ai will take all reasonable steps to ensure that your data is processed securely and in compliance with this Privacy Policy. No transfer of your Personal Data will occur to any organization or country unless adequate safeguards are in place to protect your data and personal information.

E. Data Disclosure

We may share the personal information we collect or that you provide under the following circumstances:

- Disclosure for Legal Compliance

We may be obligated to disclose your Personal Data in compliance with applicable laws or in response to legitimate requests from public authorities.

- Business Transactions

In the event that our organization or any of our subsidiaries are involved in a merger, acquisition, or sale of assets, your Personal Data may be transferred as part of that transaction.

- Other Circumstances

Additionally, we may disclose your information to:

• Our subsidiaries and affiliates.
• Contractors, service providers, and other third parties who assist our business operations.
• Fulfill the specific purpose for which you provided it.
• Feature your company’s logo on our website.
• Any other purpose we disclose to you when you provide the information.
• Obtain your consent in other situations as needed.
• Protect the rights, property, or safety of Telefony.ai, our customers, or others if we believe that such disclosure is necessary or appropriate.

F. Data Security

We prioritize the security of your data at Telefony.ai. However, it is important to understand that no method of transmission over the Internet or electronic storage is completely secure. While we endeavor to implement commercially acceptable practices to safeguard your Personal Data, we cannot guarantee its absolute security.

- Your Data Protection Rights Under the General Data Protection Regulation (GDPR)

If you reside in the European Union (EU) or the European Economic Area (EEA), you possess certain data protection rights as outlined by the GDPR. To learn more, please visit [GDPR](https://eur-lex.europa.eu/eli/reg/2016/679/oj). We are committed to taking reasonable measures to enable you to access, amend, delete, or limit the usage of your Personal Data.

For inquiries about the Personal Data we hold and to request its removal from our systems, please reach out to us at support@telefony.ai.

Under specific circumstances, you have the following data protection rights:

• Right of Access: You can request to access, update, or delete the information we hold about you.
• Right of Rectification: You are entitled to request that any inaccurate or incomplete information be corrected.
• Right to Object: You can object to our processing of your Personal Data.
• Right of Restriction: You have the right to request that we limit how we process your Personal Information.
• Right to Data Portability: You may request a copy of your Personal Data in a structured, machine readable format.
• Right to Withdraw Consent: If we rely on your consent to process your information, you can withdraw that consent at any time.

Please be aware that we may need to verify your identity before addressing your requests. Additionally, we may be unable to provide services without specific required data.

You also have the right to lodge a complaint with a Data Protection Authority regarding our collection and use of your Personal Data. Please contact your local data protection authority in the EEA for further assistance.

- Your Data Protection Rights Under the California Privacy Protection Act (CalOPPA)

CalOPPA represents the first state law requiring commercial websites and online services to post a privacy policy. Its scope extends beyond California, mandating that any individual or company that operates websites collecting personally identifiable information from California residents must have a clearly visible privacy policy. To learn more, please visit [CalOPPA](https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/).

In accordance with CalOPPA, we adhere to the following practices:

• Users may visit our site anonymously.
• Our Privacy Policy link prominently features the term "Privacy" and is easily accessible on our homepage.
• Users will be informed of any updates to our Privacy Policy via the Privacy Policy Page.
• Users can modify their personal information by contacting us at help@telefony.ai.

- Our Policy on "Do Not Track" Signals:

We respect "Do Not Track" signals and do not monitor, plant cookies, or engage in advertising when such a signal is activated. You can manage your "Do Not Track" preferences by adjusting the settings in your web browser.

- Your Data Protection Rights Under the California Consumer Privacy Act (CCPA)

As a California resident, you have the right to understand what personal data we collect about you, request its deletion, and prevent its sale or sharing. To assert your data protection rights, feel free to reach out to us with your requests.

G. Information We Hold About You

If you request the information we have about you, we will provide you with the following details:

• The categories of personal information we have collected about you.
• The sources from which we collect your personal information.
• The business or commercial purposes for collecting or selling your personal information.
• The categories of third parties with whom we share your personal information.
• The specific pieces of personal information we have collected about you.
• A list of the categories of personal information we have sold, including the categories of any other companies to whom we sold it. If we have not sold your personal information, we will notify you accordingly.
• A list of the categories of personal information that we have disclosed for business purposes, along with the categories of any other companies we shared it with.

You are entitled to request this information no more than two times in a rolling twelve-month period. When you submit this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.

- To Delete Your Personal Information

If you request that we delete your personal information, we will remove it from our records, along with directing any service providers to do the same. In some instances, deletion may be achieved through de-identifying the information. Please be aware that if you choose to delete your personal information, you may lose access to certain features or services that require your personal information to operate.

- To Stop Selling Your Personal Information

Telefony.ai does not sell your personal information for monetary gain. However, in certain situations, transferring personal information to a third party or within our group of companies may be regarded as a “sale” under California law, even without monetary consideration.

If you submit a request to opt out of the sale of your personal information, we will cease such transfers. California residents can opt out by clicking “Do Not Sell My Personal Information” located at the bottom of our homepage to submit your request.

Please note that if you ask us to delete or stop selling your data, it could affect your experience with us. You may not be able to participate in certain programs or services that rely on your personal information. However, we assure you that we will not discriminate against you for exercising your rights.

- To Exercise Your Data Protection Rights

To exercise the rights mentioned above, please send your request through one of the following methods:

• By visiting this page on our website: www.telefony.ai

Your data protection rights are protected under the California Consumer Privacy Act (CCPA). For further details, visit the official California Legislative Information website. The CCPA came into effect on January 1, 2020.

H. Service Providers

At Telefony.ai, we may engage third-party companies and individuals to provide our Service (“Service Providers”). These Service Providers help facilitate our Service, perform tasks on our behalf, and assist us in analyzing how our Service is utilized.

These third parties have limited access to your Personal Data merely to perform specific tasks for us and are obligated to keep this information confidential and not to use it for any other purpose.

- Analytics

We may utilize third-party Service Providers to monitor and analyze the usage of our Service.

- Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. It utilizes the data collected to monitor the use of our Service and shares this data with other Google services. Google may also use the collected data to contextualize and personalize ads within its advertising network. For more details on Google’s privacy practices, please visit the [Google Privacy Terms](https://policies.google.com/privacy?hl=en). We encourage you to review Google’s policy on data protection as well: [Google’s Data Safeguarding Policy](https://support.google.com/analytics/answer/6004245).

- Gleap GmBH

Gleap is an all-in-one customer feedback tool designed for apps and websites to capture user feedback visually. For more information on their privacy practices, please refer to their [Privacy Policy](https://www.gleap.io/privacy-policy).

- PostHog

PostHog tracks user behavior across our website and applications, capturing frontend and backend events. For details, visit their [Privacy Policy](https://posthog.com/privacy).

- CI/CD Tools

We may also use third-party Service Providers for automating the development process of our Service.

- Vercel

Vercel serves frontend developers, providing the speed and reliability necessary for creating excellent user experiences. More information about the data Vercel collects and its protection can be found in their [Privacy Policy](https://vercel.com/legal/privacy-policy).

- Clerk

Clerk assists developers in managing user experiences, facilitating sign-ups, sign-ins, and profile management. Visit the [Clerk Privacy Policy](https://clerk.com/privacy) for more details.

- Supabase

Supabase hosts certain types of information processed by Telefony.ai, including encrypted messages and training data. For insights into their information collection practices, please see the [Supabase Privacy Policy](https://supabase.com/privacy/).

- Hasura

Some data is processed through the Hasura GraphQL Engine. More information is available in their [Privacy Policy](https://hasura.io/legal/hasura-privacy-policy/).

- Advertising

We may engage third-party Service Providers to display advertisements to support and maintain our Service.

- AdMob by Google

AdMob, provided by Google Inc., enables us to show ads. You can opt out by following the instructions provided by Google [here](https://support.google.com/ads/answer/2662922?hl=en). For more on how Google uses collected data, visit the page on [How Google Uses Data](https://www.google.com/policies/privacy/partners/) or refer to Google’s overall [Privacy Policy](https://www.google.com/policies/privacy/).

- Behavioral Re-marketing

Telefony.ai utilizes re-marketing services to display ads on third-party websites based on your prior interactions with our Service. This involves using cookies to optimize and serve related ads.

- Google Ads (AdWords)

Google Ads re-marketing is offered by Google Inc. You can customize your ad preferences by visiting the [Google Ads Settings](https://www.google.com/settings/ads) page or install the [Google Analytics Opt-out Browser Add-on](https://tools.google.com/dlpage/gaoptout).

- Meta Platforms, Inc.

Facebook remarketing services are provided by Meta Platforms, Inc. For more information about interest-based advertising, visit this [Facebook page](https://www.facebook.com/help/164968693837950) or to opt-out, refer to the instructions found [here](https://www.facebook.com/help/568137493302217).

Facebook conforms to the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance, and you can opt-out of Facebook ads through the Digital Advertising Alliance in the USA, Canada, or Europe, or via your mobile device settings. Further details can be found in [Facebook’s Data Policy](https://www.facebook.com/privacy/explanation).

- Customer.io

Customer.io is an automated messaging platform that enables data-driven communication through emails, push notifications, in-app messages, and SMS. For additional privacy information, refer to the [Customer.io Data Policy](https://customer.io/legal/privacy-policy/).

- Payments

If we offer paid products or services, we utilize third-party services for payment processing. We do not store or collect your payment card details; this information is securely processed directly by our third-party payment processors. Their usage of your personal information is covered by their own Privacy Policies.

These payment processors adhere to PCI-DSS standards managed by the PCI Security Standards Council, which includes major brands such as Visa, Mastercard, American Express, and Discover, ensuring secure handling of payment information.

The payment processors we engage with include:

- PayPal or Braintree

Their Privacy Policy can be viewed [here](https://www.paypal.com/webapps/mpp/ua/privacy-full).

- Apple Store In-App Payments

Their Privacy Policies can be accessed at:

• [Apple Privacy Policy](https://www.apple.com/legal/privacy/en-ww)
• [Apple Support](https://support.apple.com/en-us/HT203027)

- Google Play In-App Payments

Access their Privacy Policy [here](https://policies.google.com/privacy?hl=en) and additional documents [here](https://payments.google.com/payments/apis-secure/u/0/get_legal_document).

- Paddle

Their Privacy Policy can be viewed at [Paddle Privacy Policy](https://www.paddle.com/legal/privacy).

I. Links to Other Sites

Our Service may contain links to external websites that are not operated by Telefony.ai. If you click on a third-party link, you will be redirected to that third party’s site. We strongly recommend that you review the Privacy Policy of each website you visit.

Please note that we have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

J. Children’s Privacy

Our Services are not intended for use by individuals under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us immediately. If we discover that we have collected Personal Data from Children without verifying parental consent, we will take steps to delete such information from our servers.

K. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Any changes will be communicated by posting the updated Privacy Policy on this page.

We will inform you of significant changes via email and/or through a prominent notice on our Service, prior to the changes taking effect, and we will update the “effective date” at the top of this Privacy Policy.

We encourage you to periodically review this Privacy Policy for any updates. Changes to this Privacy Policy take effect immediately upon being posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email: support@telefony.ai.