# Privacy Policy — v1 **Version:** 1.0 **Effective date:** 2026-07-28 **Status:** Platform Privacy Policy > **Notice:** This document describes how the Voice Agent Platform processes personal data. > It is provided for transparency and is **not legal advice**. Controllers remain responsible > for their own lawful bases when uploading contact data. --- ## 1. Who we are | Role | Party | |------|--------| | **Platform (Data Processor)** | CortexCraft Voice Agent Platform | | **Organisation (Data Controller)** | The customer organisation that decides what contact data to collect and why | | **Data Subjects / Data Principals** | Contacts and callers whose data is processed through the Platform | | **Sub-processors** | Google Gemini; Twilio; Plivo; Mailjet (and successors as disclosed) | --- ## 2. What we process Depending on how Controllers configure the Platform, we may process: - Account data (email, organisation name, role, authentication metadata) - Contact lists and campaign metadata uploaded by the Controller - Call records, transcripts, summaries, and related analytics - Technical logs needed to operate and secure the service We process Controller-instructed personal data **only** to provide the voice-agent service (outbound/inbound calling, campaigns, transcripts, dashboard analytics) and related support. --- ## 3. Legal bases and consent - **Account holders:** processing is necessary to create and operate the account under the Terms of Service; acceptance is recorded at signup (version + timestamp). - **Contacts / callers:** the Controller determines the lawful basis (e.g. consent, legitimate interest) and must record consent where required. The Platform stores consent fields the Controller supplies and supports withdrawal, erasure, and portability flows where enabled. --- ## 4. Sub-processors Current sub-processors used to deliver the service: - **Google Gemini** — AI conversation / voice agent inference - **Twilio** / **Plivo** — telephony connectivity - **Mailjet** — transactional email (verification, invites, notifications) Controllers are informed of material sub-processor changes via product documentation / dashboard disclosures. --- ## 5. Retention Call and related data are retained according to the Organisation’s plan retention settings and applicable platform retention jobs. Account data is retained while the Organisation’s subscription is active and deleted or anonymised after closure according to platform policy and legal obligations. --- ## 6. Rights Depending on applicable law (GDPR / DPDP and similar), Data Subjects / Principals may have rights to access, portability, erasure, and withdrawal of consent. Controllers should use the Platform’s compliance tooling (where available) or contact the Platform’s named Grievance Officer via the public grievance form at `/grievance` to exercise rights relating to Platform-held account data. --- ## 7. Security We apply industry-standard controls including encrypted credentials at rest, session cookies with HttpOnly / Secure flags, and organisational isolation of tenant data. No security measure is perfect; Controllers should also secure their own credentials and exports. --- ## 8. International transfers Where data is processed outside the Controller’s primary region, transfers rely on appropriate safeguards (e.g. contractual clauses / approved country lists) as configured for the Organisation. See the Data Processing Agreement template for Controller–Processor terms. --- ## 9. Changes We may update this Policy. The version identifier in the filename and header (e.g. `privacy-v1`, Version 1.0) changes when material updates ship. Continued use after a new version is published may require re-acceptance at a future signup or re-consent gate. --- ## 10. Contact Privacy and grievance questions: use the Platform’s named Grievance Officer and the public complaint form at `/grievance` (30-day SLA under DPDP). Officer name and contact details are published on that page. Org Compliance in the dashboard also links to this channel.