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Privacy Policy

1. Who this covers, and the two roles

This policy describes what 3-102-878347 Sociedad de Responsabilidad Limitada (company ID 3-102-878347), trading as Palancasur, of Residencia Puruses, Casa 58, Granadilla, Curridabat, San Jose, 11802, Costa Rica does with personal data.

There are two different relationships here and they must not be confused.

For the personal data of your staff, meaning the people who sign in and run your account, we decide what is collected and why. We are the controller of that data and this policy governs it.

For the personal data of your callers, meaning the people who call your business and speak with Cael, you decide what happens and we act on your instructions. You are the controller and we are the processor. The Data Processing Agreement governs that data, and where the two documents differ about your callers' data, the Data Processing Agreement wins.

2. What we collect about your staff

Account and identity: the email address used to sign in, a display name if given, the business details you enter, and which account it belongs to.

Sign-in records: a one-way hash of the address a sign-in link was requested for, a one-way hash of the link itself, the time it was requested, the time it was used, and the network address it was requested from. The link itself is never stored in a form we can read.

Legal acceptance records: which document version was accepted, the hash of that version's exact text, who accepted it, when, the network address the acceptance came from, and the browser user agent string. Those last two are personal data and they are collected deliberately. They are the corroborating detail that makes a record of consent worth anything if it is ever questioned.

Operational records: an audit log of what happened in your account, which records identifiers, states and timings. It does not record what a caller said, and it does not record a dialable phone number.

Billing records: what was used, when, and what it cost. Card details are entered on the checkout of our merchant of record and are never sent to us.

3. What we collect about your callers

  • The caller's phone number and the times of their calls.
  • Call audio. It is processed in real time to transcribe the call and to produce Cael's spoken replies. We do not store recordings of the call audio.
  • Call transcripts, meaning the text of what the caller and Cael said.
  • Booking details: the job or appointment requested, and when it is booked.
  • The caller's name. Cael asks for it before booking any appointment, so your business knows who is coming, or who booked. It is stored with the appointment and the customer record.
  • The service address, but only for on-site work. When a job is done at the caller's location rather than at your place of business, Cael asks for the address and reads it back once to confirm it, and stores it with that appointment. For a job done at your place of business, no address is asked for and none is stored.
  • Whatever else the caller chooses to say during the call, which appears in the transcript.

This is the data you are the controller of. See the Data Processing Agreement.

4. Why we collect it

To run the service you asked for: answering your calls, showing you what was said and what was booked, and sending you the operational email the service produces, such as a new booking or a caller who needs you. To bill you accurately and to reconcile what our suppliers charge us. To keep evidence that you accepted the agreements you accepted. To detect and stop abuse of the service and to find and fix faults in it.

We do not use any of it for advertising. We do not sell it and we do not share it for advertising.

5. Who else processes it

The following suppliers process personal data on our instructions in order to run the service:

  • Railway, application and database hosting, United States.
  • Telnyx, telephone numbers and call delivery, United States.
  • LiveKit, real-time transport of call audio, United States.
  • Deepgram, speech-to-text transcription of call audio, United States.
  • Cartesia, text-to-speech for Cael's voice, United States.
  • Anthropic, the language model that decides Cael's replies, United States.
  • Resend, transactional email, United States.
  • Polar Software, Inc., merchant of record for subscription payments. Polar processes your billing details and does not receive call data.
  • Sentry, error monitoring, United States, once it is enabled for the service.

Two further suppliers are used only in the circumstances stated:

  • Google, calendar availability and bookings, United States, only if you connect a Google calendar to your account.
  • Twilio, text messages, United States, only if text messaging is offered and switched on for your account.

We do not add a supplier that processes personal data without updating this list, and for your callers' data the notice and objection process in the Data Processing Agreement applies.

6. Where it is processed

We are established in Costa Rica. The suppliers above process data in the United States. Personal data covered by this policy is therefore processed outside Costa Rica and outside the country of residence of anyone who is elsewhere.

7. How long it is kept

Call audio is not stored. Transcripts, booking details, the caller's name, the service address and the other data described in section 3 are kept while your account is open, so that you can see your call history. The caller's name and service address are deleted together with the rest of that caller's record: our retention rule keeps a caller's contact details, including their name, address, conversations, calls and appointments, for 25 months after their last contact with your business, then deletes them.

If you or one of your callers asks us to delete a caller's data, we delete it within 30 days of the request, subject to the exceptions below. When your account closes, your callers' data is deleted in line with our retention schedule. Automatic deletion on a fixed schedule is not yet running for open accounts, and this policy does not promise it. When it is switched on, the windows will be stated here and will be generated from the same configuration the service runs on.

Two things are kept for longer, because they follow from the design rather than from a setting:

  • Legal acceptance records are kept for as long as they might be needed as evidence. A record of consent that has been deleted proves nothing.
  • Billing records are kept for the period tax and accounting law requires.

8. Security

Access to production data is limited to the people who need it. The application connects to the database as a role that cannot read another account's rows, enforced by the database rather than by application code. Acceptance records and the audit log cannot be updated or deleted by the application at all, because the database does not grant it those rights. Credentials held for third party services are encrypted at rest. Traffic between components is encrypted in transit.

9. Your rights

If you are a member of staff on an account, you may ask for a copy of the personal data we hold about you, ask for it to be corrected, or ask for it to be deleted. Write to info@palancasur.com.

One limit is stated plainly rather than discovered later: a request to delete personal data will not remove a legal acceptance record, because that record is the evidence that an agreement was made. Where possible we will remove the personal detail from it and keep the proof.

Requests from your callers about their own data go to you, because you are their controller. We will help you answer them. See the Data Processing Agreement.

10. Cookies

The service sets one cookie, which holds your signed-in session. It is required for the service to work and it is not used for tracking or advertising. There is no analytics script and no third party tag.

11. Changes

This policy is versioned in the same way as the other documents, and a change that alters what we do with personal data carries a new major version and is put in front of you for acceptance.

12. Contact

3-102-878347 Sociedad de Responsabilidad Limitada, Residencia Puruses, Casa 58, Granadilla, Curridabat, San Jose, 11802, Costa Rica. Email info@palancasur.com.