Last updated: 13 October 2026
1. Roles
The Customer is the controller of personal data in its calls, recordings, transcripts, contacts and other Customer Data. CallCleverly is the processor and processes that data only on the Customer's documented instructions, which are these Terms, this agreement and the Customer's use and settings of the Service.
2. What is processed
| Subject matter | Providing the CallCleverly Service |
|---|---|
| Duration | For as long as the Customer uses the Service, plus the deletion period in section 9 |
| Data subjects | People who call or are called by the Customer, the Customer's contacts and leads, and the Customer's team members |
| Types of data | Names, phone numbers, email addresses, voice recordings, transcripts, summaries, survey answers, booking details and any other data the Customer chooses to collect |
| Purpose | Answering and making calls, transcribing and summarising them, bookings, tasks, surveys, reports and integrations the Customer switches on |
3. Our obligations
- Process Customer Data only on the Customer's instructions, unless the law requires otherwise (we will tell the Customer where allowed).
- Make sure staff with access are bound by confidentiality.
- Keep appropriate technical and organisational security measures, including encryption in transit, access controls and logging.
- Help the Customer respond to data subject requests and with security and impact assessments, taking into account the nature of the processing.
- Notify the Customer without undue delay after becoming aware of a personal data breach affecting Customer Data.
4. Sub-processors
The Customer authorises us to use these sub-processors:
| Sub-processor | Service |
|---|---|
| Hosting provider (European Union data centres) | Servers, database and storage |
| Google (Gemini API) | AI speech, transcripts and summaries |
| Stripe | Payments (billing data only) |
Telephony providers, calendars, CRMs and other tools that the Customer connects are engaged by the Customer, not by us. We will give at least 30 days' notice before adding or replacing a sub-processor, and the Customer may object on reasonable data protection grounds.
5. International transfers
Where Customer Data is transferred outside the country where it was collected, we ensure appropriate safeguards are in place as required by applicable law.
6. Customer obligations
The Customer is responsible for having a lawful basis for the processing, giving callers any required notices (including about AI and recording), and the lawfulness of the data it provides.
7. Audits
On reasonable written request, and no more than once a year, we will provide information needed to show compliance with this agreement.
8. Liability
Liability under this agreement is subject to the limits in our Terms of Service.
9. Deletion
When the Customer's account ends, we delete Customer Data within 30 days (after any export the Customer requests), unless the law requires us to keep it.
10. Contact
Data protection questions: info@callcleverly.com.