Privacy Policy

Privacy Policy - Dialer

Introduction

Dialer ("we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, process, and protect your personal data when you use our dialer application and services available at https://getdialer.app/ (the "Service").

Our Service enables Large Language Models (LLMs) to make outbound phone calls using your phone number, with call recording capabilities for your review. This policy describes our data practices, your rights, and how we comply with applicable privacy laws including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and Telephone Consumer Protection Act (TCPA).

Information We Collect

Personal Information Categories

Contact and Identity Information:

  • Your phone number (primary and alternative numbers)
  • Contact information (name, email address, billing address)
  • Account credentials and authentication data
  • Identity verification information

Call and Communication Data:

  • Phone numbers you call (recipient numbers)
  • Call recordings (audio files of your conversations)
  • Call metadata (date, time, duration, connection status)
  • Call transcripts (generated from recordings)

Technical and Usage Information:

  • Device information (type, operating system, unique identifiers)
  • IP address and location data
  • Service usage patterns and preferences
  • Performance and diagnostic data
  • Error logs and crash reports

Collection Methods

We collect information through:

  • Direct provision when you create an account or use our services
  • Automatic collection through your use of our application
  • Third-party services including Twilio, ElevenLabs, and Vercel

Legal Basis for Processing

We process your personal information based on the following legal grounds:

Consent (GDPR Article 6(1)(a)):

  • Call recording
  • AI voice generation and synthesis
  • Marketing communications (where applicable)

Contract Performance (GDPR Article 6(1)(b)):

  • Providing dialer services and call connectivity
  • Managing your account and billing
  • Customer support and service delivery

Legitimate Interests (GDPR Article 6(1)(f)):

  • Service improvement and technical optimization
  • Fraud prevention and security monitoring
  • System maintenance and troubleshooting

Legal Obligation (GDPR Article 6(1)(c)):

  • Compliance with telecommunications regulations
  • Data retention for legal and regulatory requirements
  • Responding to law enforcement requests

How We Use Your Information

Primary Purposes

Service Delivery:

  • Connecting and routing your phone calls through our telephony infrastructure
  • Providing customer support and technical assistance

Account Management:

  • Creating and maintaining your user account
  • Processing payments and billing
  • Communicating about service updates and changes
  • Managing your preferences and settings

Security and Compliance:

  • Detecting and preventing fraud and unauthorized access
  • Maintaining system security and integrity
  • Complying with legal obligations and regulations
  • Responding to legal requests and court orders

Important: No Commercial Use

We do not use your personal information for commercial purposes, marketing campaigns, or analytical insights beyond what is necessary for service functionality. Your data is processed solely to deliver the dialer services you request.

Third-Party Data Processing

Twilio (Telephony Services)

Data Processed: Phone numbers, call transcripts, call metadata, voice data

Purpose: Telecommunications services, call routing, and connectivity

Location: United States (certified under EU-U.S. Data Privacy Framework)

Retention: 30-60 days after service termination

ElevenLabs (AI Voice Generation)

Data Processed: Transcripts, voice synthesis data, audio content

Purpose: AI voice generation and speech synthesis

Location: United States, Netherlands, Singapore

Retention: Maximum 3 years after last interaction

Vercel (Web Hosting)

Data Processed: Account data, usage analytics, performance metrics

Purpose: Web hosting, content delivery, and infrastructure services

Location: United States (certified under EU-U.S. Data Privacy Framework)

Retention: Commercially reasonable timeframe

All third-party processors operate under comprehensive Data Processing Agreements (DPAs) with appropriate security safeguards and international data transfer protections.

AI and Automated Decision-Making

AI Voice Technology Disclosure

Our service uses artificial intelligence to generate voice content. When you use our AI voice features:

  • AI-generated voices may sound like human speakers

Automated Decision-Making

We may use automated systems for:

  • Fraud detection and prevention
  • Call routing optimization
  • Quality assurance monitoring
  • Security incident response

You have the right to object to automated decision-making that produces legal effects or significantly affects you.

Call Recording and Consent

Recording Practices

All calls made through our service may be recorded for quality assurance and service improvement purposes. We comply with applicable call recording laws:

Data Security

Technical Safeguards

  • Encryption: All data is encrypted in transit (TLS 1.3) and at rest (AES-256)
  • Access Controls: Role-based access with multi-factor authentication
  • Monitoring: 24/7 security monitoring and incident response

Organizational Safeguards

  • Training: Regular privacy and security training for all personnel
  • Policies: Comprehensive data handling and incident response procedures

Your Privacy Rights

Universal Rights

  • Access: Request copies of your personal data
  • Rectification: Correct inaccurate information
  • Deletion: Request deletion of your personal data
  • Portability: Receive your data in a machine-readable format
  • Restriction: Limit how we process your data
  • Objection: Object to certain types of processing

Jurisdiction-Specific Rights

GDPR Rights (EU Residents):

  • Right to withdraw consent at any time
  • Right to object to automated decision-making
  • Right to lodge complaints with supervisory authorities
  • Right to data portability

CCPA Rights (California Residents):

  • Right to know what personal information is collected
  • Right to delete personal information
  • Right to opt-out of sale (Note: We do not sell personal information)
  • Right to non-discrimination for exercising rights

TCPA Rights (US Residents):

  • Right to revoke consent for calls and texts
  • Right to be added to internal Do Not Call lists
  • Right to request call recording cessation

Exercising Your Rights

Contact Methods:

  • Email: privacy@getdialer.app
  • Online: Account settings and privacy portal

Response Time: We will respond to requests within 30 days (extendable to 90 days for complex requests)
Verification: We may require identity verification to process certain requests

Children's Privacy

Our service is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, please contact us immediately.

Changes to This Privacy Policy

Update Notifications

We will notify you of material changes to this privacy policy:

  • Email notification to registered users

Your Options

For material changes, you may:

  • Continue using our service under the updated policy
  • Withdraw consent for new processing activities
  • Request account deletion if you disagree with changes
  • Contact us with questions or concerns

Contact Information

Privacy Officer

  • Email: privacy@getdialer.app

General Contact

  • Company: Dialer
  • Website: https://getdialer.app/
  • Email: support@getdialer.app

Regulatory Complaints

  • EU Residents: Contact your local Data Protection Authority