Data processing agreement

This agreement applies between the business that uses AnsweredRing (the “controller”) and [Company name B.V.] (the “processor”). It forms part of the terms of service and meets the requirements of Article 28 of the General Data Protection Regulation (GDPR).

• Purpose: answering the controller’s inbound phone calls with an AI assistant, transferring calls to the controller’s staff, and showing the controller a record of each call.
• Data subjects: people who call the controller’s phone numbers.
• Data: the caller’s phone number, the number called, time and duration of the call, the outcome, what the caller and the assistant said (transcript), and a short summary. Callers may mention any information during a call, including sensitive information.
• Audio: call audio is processed live to convert speech to text and text to speech. The platform does not store call recordings.

The processor processes this data only to provide the service as configured by the controller, and on the controller’s documented instructions. If the processor believes an instruction breaks the law, it tells the controller.

• The controller sets how many days transcripts and summaries are kept (default 90). Older ones are erased automatically every night.
• The controller’s account owner can erase the transcript and summary of a single call at any time.
• The call record without content (time, duration, numbers, outcome) is kept for billing.
• After the account is closed, the processor deletes the controller’s call data, except where the law requires it to be kept.

People working for the processor are bound by confidentiality. Platform administrators can see call records without content; they cannot open caller numbers, transcripts or summaries through the administration panel.

• Each customer’s data is separated and every request is checked against the customer’s account.
• Passwords are stored as salted hashes; sessions can be ended centrally.
• Connections to the service are encrypted in transit.
• Changes made by platform administrators are recorded in an audit log.

[Describe hosting location, encryption at rest and backup arrangements here once the production environment is chosen.]

The controller gives general permission to use sub-processors for the functions below. The processor informs the controller before adding or replacing one, so the controller can object.

• Telephone carrier — delivers the calls.
• Real-time media platform — connects the call to the assistant.
• Speech-to-text provider — turns the caller’s speech into text.
• Language-model provider — produces the assistant’s answers and the call summary.
• Text-to-speech provider — turns the answers into speech.
• Hosting provider — runs the platform and its database.

[Name each provider, its location and the transfer safeguard here before publishing.]

The processor helps the controller answer requests from data subjects and carry out data protection impact assessments. The processor reports a personal data breach affecting the controller’s data without undue delay after becoming aware of it, with the information the controller needs to meet its own duties.

On request the processor provides the information needed to show compliance with this agreement and allows an audit, at most once a year and with reasonable notice, unless a breach gives reason for more.

This agreement lasts as long as the processor processes personal data for the controller.