Privacy Policy

1. Who we are

Caller.ee is a call quality analysis service operated by Sumgrey OÜ, Olevi 30-77, Kohtla-Järve, Estonia ("we"). This policy covers the application at app.caller.ee, its API, the documentation at docs.caller.ee and the website caller.ee.

For any question about this policy or about your data, write to caller@sumgrey.com. We have not appointed a data protection officer; that address reaches the person responsible for data protection.

2. Two kinds of data, two roles

Account data is the data about you as the holder of an account, or as a person the holder has given access to theirs: your email address, your settings, what you have used of your plan. We decide why and how it is processed, so for it we are the controller. Sections 3 to 9 are about account data.

Customer content is what you put into the service: call recordings and what is produced from them, your scorecards and documents, your agents, clients and campaigns. It usually contains personal data of the people on the calls. You decide what is uploaded and why, so for it you are the controller (or the processor of your own clients) and we are your processor: we handle it only to provide the service, on your instructions, under the Data Processing Agreement that forms part of the Terms of Service. Section 10 describes how it is handled.

If you are a person who appears in a recording, the organisation that recorded the call is responsible for it: ask them. If you write to us, we will pass your request to that organisation.

3. The account data we collect

• Sign-in details: your email address, your name if you give it, and your password, which is stored only as a salted hash that cannot be read back.
• One-time codes: the codes emailed to you to confirm your address or to change a forgotten password. They expire after 15 minutes.
• Settings: interface language, time zone and your privacy options.
• Access to somebody else's account: if the holder of an account invites you to it, we keep your email address with the invitation and send you an email to tell you; an invitation that is not accepted expires after 14 days. If you accept it, we keep what you may do in that account and, if you are one of its agents or of its clients, which entry your access belongs to. In accounts whose plan includes it, an activity log keeps for a year which person made certain changes (inviting people or removing access, creating keys, deleting calls, correcting scores), for the administrators of the account to consult.
• The record that you accepted the Terms and this policy: which edition, and when.
• Plan and usage: your plan, the minutes of audio and the storage you have used, and the counters that enforce the limits of the plan.
• Integration settings: the names of your API keys (the keys themselves are stored only as hashes) and the address of your webhook.
• Messages you send us, such as support emails.
• Technical data: the cookies that keep you signed in, and server logs about the operation of the service (errors, timings, internal identifiers), which may include IP addresses.

An email address and a password are needed to have an account; everything else is optional. We do not obtain data about you from other sources.

4. Why we use it, and on what legal basis

We do not use your data for advertising, we do not sell it, and we take no decision about you by automated means alone.

5. Who else handles the data

We run the service with the providers below. Each one acts on our instructions under a data processing contract and may use the data only for the task described. Nobody else receives your data, unless a law or a court order obliges us to hand it over.

When paid plans are introduced, payments will be handled by Stripe Payments Europe, Limited (Ireland). This list will be updated, and you will be told, before that happens.

6. Where the data is processed

The application and its database run on a server in Nuremberg, Germany. Recordings and documents are stored, and the AI models run, in Paris, France. Recordings are transcribed by Speechmatics in the region it operates inside the European Union.

Speechmatics is a company based in the United Kingdom, a country covered by an adequacy decision of the European Commission (in force until 27 December 2031). Where one of our providers needs to transfer data outside the European Economic Area, it does so under an adequacy decision or the European Commission's standard contractual clauses. Google Analytics, used only on the website and only with your consent, may transfer data to the United States under the EU–US Data Privacy Framework.

7. How long we keep it

• Account data: for as long as the account exists. Deleting your account in Settings erases it at once, together with everything the account contains.
• Access to somebody else's account: until you delete it in Settings, an administrator of that account removes it or the account is deleted. Your sign-in details are erased at that moment; the account and its content remain its holder's.
• After an account is deleted: for 12 months we keep a fingerprint of its email address together with what the account had used of its plan (the minutes of the current period and the storage). The fingerprint is a keyed cryptographic hash: it lets us recognise the same address if it signs up again, but it cannot be turned back into the address and nothing else about the account is kept with it. Its only purpose is that deleting an account and creating it again does not start the free allowances afresh. It is pseudonymised personal data, processed on the basis of our legitimate interest; you can object to it by writing to us. An account that had used nothing leaves nothing.
• The counters that limit how many codes are sent to one address hold a hash of that address for about a day.
• Server logs are overwritten as they fill up; they are not kept as an archive.
• Messages you send us: for as long as needed to deal with them and to keep a record of what was agreed with you.
• Backups: before maintenance work we may take a backup copy of the database. Backups are deleted within 30 days, and what you have deleted disappears from them when they are.
• Invoices, once paid plans exist: for the period that accounting law requires.

8. Your rights

You have the right to access your data, to have it corrected or erased, to restrict or object to its processing, to receive it in a portable format and to withdraw any consent you have given. You can object in particular to processing based on our legitimate interests, including the fingerprint described in section 7.

Much of this is self-service: in Settings you can change your details, download your account data as a file and delete your account with everything in it. For anything else, write to caller@sumgrey.com; we answer within one month.

If you believe we handle your data unlawfully you can complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, Estonia (aki.ee), or to the data protection authority of the country where you live or work.

9. Cookies

The application uses only the cookies it needs to work: those that keep you signed in and one that remembers your language. They are not used to track you and need no consent. The application and the documentation contain no analytics or advertising.

The website caller.ee uses Google Analytics to count visits. Its cookies are set only if you accept them in the cookie notice, and you can change your choice at any time.

10. The calls you upload

This is what happens to a recording:

1. It is uploaded over an encrypted connection and stored by Scaleway in Paris.
2. It is sent to Speechmatics, which turns it into text in its region in the European Union. As soon as we have the transcript we delete the recording and the transcript from Speechmatics; should that deletion fail, Speechmatics deletes them itself after 7 days. Speechmatics does not use them to train its models.
3. The transcript is sent, together with your scorecard and the passages of your knowledge base that apply, to AI models that Scaleway runs in Paris, which score the call. If you have turned PII redaction on, the identifiers it covers are removed from the transcript before this step. Scaleway does not keep the requests or the answers after processing them and does not use them for training; it may keep the content of a request for up to two weeks only if it detects malicious activity. The companies that created the models have no access to any of it.
4. The transcript and the analysis are stored in our database, on a server in Nuremberg. So that you can search your calls by meaning, passages of the transcript are indexed by a model that also runs at Scaleway in Paris.
5. The assistant in the application answers your questions from the data of your account, using the same models.

We do not use your content to train or improve AI models, ours or anyone else's. We do not sell it and do not share it with anyone other than the providers in section 5. Each account's content is kept separate from every other account's. Our own staff look at the content of an account only when you ask us for help, or when it is needed to fix a fault or to protect the service.

PII redaction is optional and can be set for the whole account or per campaign. When it is on, email addresses, phone numbers, IBANs, payment card numbers and Spanish national identity numbers (DNI and NIE) are masked in the transcript before it is stored or analysed. Detection works by patterns: it does not detect names or postal addresses, and a number dictated digit by digit can remain. It does not alter the recording: the transcription provider always receives the whole recording, and the audio you can play back is the original.

Your content is kept until you delete it. Deleting a call removes its recording, its transcript, its analysis and the values of its custom fields at once; what remains is a record with no content (dates, duration and the minutes it used). Deleting your account removes everything.

11. Artificial intelligence

• Transcripts, scores, summaries and the assistant's answers are produced by AI and can be wrong. Each score comes with the passages of the transcript it rests on, so that a person can check it, and can be corrected by hand.
• The service does not analyse voices to infer emotions. The customer sentiment it reports is read from what the customer says in the transcript; it never assesses the emotions of the people who work for you.
• The service takes no decisions about anybody. What you do with its results is your decision; the Terms set out what the law expects from you when those results are about people who work for you.

12. Security

• All traffic to the service, and between the service and its providers, is encrypted in transit.
• Every request is authenticated and limited to its own account in the data layer, so one account can never read another's content.
• Passwords and API keys are stored only as hashes. Recordings are played through short-lived links tied to your session.
• The providers that host and process the data hold ISO/IEC 27001 certification.
• The copy of a recording held by the transcription provider is deleted as soon as it has been used.

We hold no security certification of our own yet. If a security breach affects your data, we will tell you without undue delay.

13. Changes to this policy

We will announce material changes, including any new provider that handles your content, by email or in the application at least 30 days before they apply. The edition you accepted is recorded with your account.