Callsy AI OÜ is a private limited company registered in the Republic of Estonia, with its registered address in Estonia.
In relation to personal data collected through our website (callsy.ai) and in our direct relationship with clients and contacts, Callsy AI acts as a data controller under the EU General Data Protection Regulation (GDPR).
In relation to advertising performance data and API credentials processed on behalf of our clients as part of the Sofia service, Callsy AI acts as a data processor. The client is the data controller in that relationship, and processing is governed by our Data Processing Agreement (DPA).
Legal basis: performance of a contract and pre-contractual measures (Article 6(1)(b) GDPR); legitimate interests (Article 6(1)(f) GDPR).
Legal basis: performance of a contract (Article 6(1)(b) GDPR); legal obligation — Estonian accounting law requires retention of financial records for 7 years (Article 6(1)(c) GDPR).
We store encrypted API credentials provided by clients to enable Sofia to connect to Meta Ads and Google Ads accounts:
Stored in encrypted form on isolated, client-dedicated infrastructure. Deleted within 30 days of contract termination.
Legal basis: performance of a contract (Article 6(1)(b) GDPR).
Campaign metrics, creative performance data, spend, impressions, clicks, and conversion events. This data does not typically include personal data about the client's end-users.
Retention: Performance snapshots retained for up to 90 days.
Sofia operates as a Slack bot within the client's workspace. Message content is processed to generate responses and retained within the agent's conversational context. Context is cleared upon contract termination.
| Sub-processor | Location | Purpose |
|---|---|---|
| Anthropic (Claude AI) | United States | AI inference engine. Transfer mechanism: Standard Contractual Clauses (SCC). |
| Hetzner Online GmbH | Germany (EU) | Dedicated VPS hosting per client. All servers in EU data centres. |
| Slack Technologies LLC | United States | Messaging platform for Sofia's Slack bot delivery. |
Transfers to Anthropic and Slack Technologies are conducted under Standard Contractual Clauses (SCCs) approved by the European Commission under Article 46(2)(c) GDPR.
| Data Category | Retention Period |
|---|---|
| API credentials | Deleted within 30 days of contract termination |
| Advertising performance snapshots | Deleted after 90 days from collection |
| Slack conversation context | Cleared upon contract termination |
| Billing and invoice records | 7 years (Estonian Accounting Act) |
| Client contact data | Duration of contract + 2 years |
Under the GDPR, you have the following rights:
Contact: privacy@callsy.ai. We will respond within 30 days.
You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee).
We will provide 30 days notice for material changes to this Privacy Policy.
Callsy AI OÜ
Email: privacy@callsy.ai