Privacy Policy

1. Introduction

Call Whisperer ("we", "our", "us") provides an AI-powered sales coaching platform. Depending on your plan and settings, that may include practice sessions, live telephone calls with real-time coaching, and optional contact-memory features that help you prepare for future calls. This Privacy Policy explains how we collect, use, and protect information when you use our service.

2. Information We Collect

Account Information

When you create an account, we collect your email address and any profile information you provide.

Practice Session Data

During practice sessions, we process call audio, generate real-time transcriptions, and create AI coaching feedback. This includes conversation transcripts, coaching suggestions, and post-session analysis scores.

Usage Data

We collect information about how you use the service, including pages visited, features used, session frequency, and performance metrics. This data helps us improve the product and understand user engagement.

Live Client Call Data

If you use live calls, we process telephony and call-related data needed to place and coach the call. That can include numbers you register or dial, call metadata (for example start/end time, duration, disposition), streamed or recorded audio, transcripts, AI coaching outputs, summaries, and related technical logs. Separate detail is in the "Live Client Calls" section below, including records of blocked call attempts to restricted destinations.

Contact Memory and Business Contact Data

If you use contact memory, you may store business details about people and organisations you call or import — for example names, phone numbers, emails, employer or account links, and notes or confirmed business facts. The Service may also suggest candidate facts from a call transcript for you to confirm or discard. Separate detail is in the "Contact Memory" section below.

3. How We Use Your Information

• Provide and operate the AI sales coaching service
• Generate real-time coaching feedback during practice and live calls
• Produce post-session analysis, summaries, and improvement recommendations
• Store and surface contact memory you choose to keep, and ground coaching or prep only on confirmed, non-stale facts where the product supports it
• Support export, correction, and deletion of your data, including your contact book
• Track your practice and calling history and progress over time
• Enforce usage limits, security controls, and prevent abuse (including blocked-destination handling)
• Improve our models and service quality using aggregate or service metrics; we do not use your third-party contact-book contents to train foundation models shared across customers
• Communicate with you about service updates

4. Third-Party Services

We share data with third-party service providers as necessary to operate the platform — for example hosting, authentication, analytics, telephony carriers or platforms, speech-to-text, and AI model providers. These providers may receive account information, usage data, session-related data, live-call audio or transcripts, or contact-memory fields solely to perform services on our behalf. They are not permitted to use your data for their own purposes. Each operates under its own privacy policy, and we only share the minimum data necessary for the Service to function.

5. Data Storage and Security

Your data is stored securely using industry-standard controls, including row-level security policies so that, in normal operation, you can only access your own account data and contact book. We use encryption in transit (TLS/SSL) for communications. Practice data, live-call records, and contact-memory records are stored in our systems and associated with your account.

6. Data Retention

How long we keep data depends on the category. You can usually delete sooner using the product or by contacting us. We may keep information longer when required for security investigations, disputes, legal compliance, or abuse prevention.

• Account and practice history: retained while your account is active, unless you delete data or close your account earlier.
• Live-call audio, transcripts, and call-linked coaching outputs: retained while your account is active, subject to any shorter operational schedule we apply and to deletion or account-closure requests.
• AI candidate facts suggested from a call transcript are held with the call for your review and are not kept as a separate standing profile. If you do not confirm or discard them, they are automatically removed within 30 days.
• Contact records and confirmed facts (person and account layers): up to 24 months after the last qualifying activity for that person or account (for example a call with a recorded disposition, a confirmed fact update, or an explicit save you make), unless you delete sooner. Simply viewing a profile, appearing in search, or being added to a queue without a call or confirm does not reset this clock. Import-only contacts with no later call or confirm age from import (or from an as-of date you supply), not from passive re-imports of the same number.
• Impressions (short-lived observations that are not durable facts): up to 90 days, then removed.
• Blocked call-attempt records: up to 12 months, unless needed longer for security, disputes, compliance, or abuse prevention (see Live Client Calls).

When you close your Call Whisperer account, we delete or irreversibly anonymise your contact book and associated service data on the timelines that apply to account erasure, except where we must retain limited records for legal or security reasons.

7. Your Rights

Depending on where you live and your relationship to the Service, you may have the right to:

• Access personal data we hold about you, including practice history and, for account holders, your contact memory
• Request correction of inaccurate information (including by updating or replacing facts in the product where available)
• Request deletion of your account, practice data, live-call data we control for your account, and your contact book
• Export practice session data and, where contact memory is enabled, export contacts and person- and account-layer facts in a structured file or via a support-fulfilled request with the same completeness
• Object or restrict certain processing, and opt out of marketing communications, where applicable

How to exercise: use in-product controls where offered, or email privacy@callwhisperer.app. We may need to verify your request. Some requests about people named only in a customer's contact book are handled as described in "People Named in Your Contact Book" below.

8. Cookies and Tracking

We use cookies and similar tracking technologies for authentication, analytics, and advertising. Our analytics and advertising tools may collect information about your browsing behavior. You can manage your cookie preferences through your browser settings.

9. Children's Privacy

Our service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children.

10. Changes to This Policy

We reserve the right to update this Privacy Policy at any time at our sole discretion. Changes take effect immediately upon being posted to this page, as reflected by the updated date at the top. We may, but are not obligated to, notify you of changes. It is your responsibility to review this Policy periodically. Your continued use of the Service following any changes constitutes your acceptance of the revised Policy.

11. Live Client Calls

Live calls let you place real telephone calls while the Service provides transcription and AI coaching. Live calls are different from practice sessions with simulated buyers.

What we process

Depending on how you use the feature, this may include: telephone numbers you register or verify; caller-ID and telephony setup identifiers; numbers you dial; call metadata (times, duration, disposition, routing outcomes); streamed or recorded audio; transcripts; AI coaching suggestions and related outputs; call summaries and notes; links from a call to a contact in your book; and technical logs needed to operate, bill, secure, and support the feature.

After some calls, the Service may extract candidate business facts from the transcript for you to confirm or discard. Candidates stay with the call record and are not treated as durable contact-memory facts until you confirm them; if left unconfirmed they are automatically removed within 30 days. Confirmed facts are described under Contact Memory.

Why we use it

To provide live coaching and related features you enable; to generate summaries and candidate facts for your review; to operate telephony; for security, fraud and abuse prevention, billing and disputes, support, debugging, legal compliance, and service improvement in line with this Policy.

Your responsibilities (summary)

You are responsible for complying with call-recording, monitoring, telemarketing, do-not-call, and privacy laws that apply to your calls, including obtaining any required consents and giving any required notices to people on the call. Call Whisperer does not obtain consent from callees on your behalf. Details also appear in the Terms of Service (Live Client Calls).

Blocked call attempts

We restrict certain destinations and number ranges for security, fraud-prevention, cost, carrier, and legal reasons. When you attempt to call a restricted destination, we record the attempt so we can keep the Service secure and understand demand for destinations we do not yet support.

What we collect: the number dialled, your account and user identifiers, the date and time of the attempt, the destination classification, the reason the destination was restricted, and related request metadata.

Why we use it: security, fraud prevention, abuse prevention, billing and dispute handling, support and debugging, legal compliance, service improvement, and cost control.

Legal basis (UK/EEA) for blocked attempts and related service security data: our legitimate interests in operating a secure, sustainable service, and, for account holders, performance of our contract with you.

Retention: we keep blocked call-attempt records for up to 12 months, unless we need them longer for a security investigation, dispute resolution, legal compliance, or abuse prevention.

Sharing: we may share live-call and blocked-attempt data with the telephony, hosting, security, AI/transcription, analytics, and support providers that help us operate the Service, limited to what is needed.

12. Contact Memory and Business Contact Data

Contact memory (shown in the product in places as what you know about people you call) is an optional working book of businesscontact details and notes. It is not a public people-search product, and we do not market it as a "GDPR-compliant CRM" or as a substitute for your own compliance programme.

Categories

Depending on what you store or enable, this may include:

• Contact and account records — names, phone numbers, emails, company or account associations, and related timestamps
• Person-layer and account-layer facts — confirmed business notes (for example budget, decision process, competitors, renewal timing) with confidence, source, and dating metadata
• Impressions — short-lived observations that fade on a shorter schedule than confirmed facts
• AI candidate extraction — suggested facts from a call transcript, held on the call until you confirm, edit, or discard them, or until they are automatically removed after 30 days if left unconfirmed
• Confirm and grounding metadata — what you confirmed, when, provenance (including transcript quotes stored as source), and whether a fact may be used to ground coaching or prep
• Import files and mappings — if you import a working list or CRM-style export, the file contents and column mapping needed to run the import, together with your confirmation that you are authorised to contact the people on it
• Links between contacts and your live calls where the product associates them

How we use contact memory

We process contact memory to provide the Service to you, at your direction: prep and coaching context, showing staleness, confirming or replacing facts, and enabling export and deletion. Coaching features that ground on memory are designed to use confirmed, non-stale facts — not unconfirmed AI candidates. We do not use your contact book to build an independent commercial profile of third parties across customers.

Who is responsible (plain language)

You (the customer / rep account holder) are the controller of your contact book: you decide who is in it, what is confirmed, what is imported, and who you call. Your lawful basis for that processing is typically your legitimate interests in B2B sales or customer management, or another basis you determine — not a consent checkbox Call Whisperer shows to you about our Service terms.

Call Whisperer acts as a processor for contact memory we handle to provide the Service to your account (store, extract candidates for your review, ground coach features you use, and export or delete on your instruction). Call Whisperer is a controller of your own account data, billing, security and abuse data, and similar service records.

You must only upload or store contact information you are authorised to process. You remain responsible for telemarketing, do-not-call / TPS / CTPS, privacy notices to individuals, and other laws that apply to your calling and lists. Call Whisperer does not obtain consent from callees for your contact book, and does not claim to discharge your do-not-call or telemarketing duties. Importing a list is treated as your working book or a CRM export, not a purchased bulk cold list, and we do not screen imports against statutory do-not-call registers.

Content limits

Contact memory is for business-relevant information. Do not use it to collect special-category or similarly sensitive personal data about contacts (for example health, ethnicity, political or religious beliefs). Product rules also aim for notes a professional would be comfortable with the contact reading if they ever saw them.

Retention (contact memory)

Confirmed contact and account facts default to a maximum of 24 months after last qualifying activity for that person or account, unless you delete sooner. Impressions last up to 90 days. Unconfirmed AI candidates are not kept as a separate standing profile; if you do not confirm or discard them, they are automatically removed within 30 days. See Data Retention above for the full schedule.

Export and deletion

You may export or delete contacts and facts through the product where offered, or by contacting privacy@callwhisperer.app. Export is intended to cover your contacts, person-layer facts, and account-layer facts you own (clearly tagged), with provenance where stored.

Deleting one person removes their person-layer facts and unconfirmed candidates tied to them. Company-level (account-layer) facts may remain if other people from that organisation stay in your book. Live-call audio and transcripts are a separate record class: removing a contact unlinks the person from the call where applicable and does not automatically wipe every related recording unless you also delete those call records or close your account under the applicable process.

Closing your Call Whisperer account removes your contact book as part of account erasure.

13. People Named in Your Contact Book (Third Parties)

If you are a person whose business contact details appear only because a Call Whisperer customer stored them in their working book, the primary responsibility for that processing sits with that customer (the controller). Call Whisperer processes that book to provide the Service to the customer.

You may still contact us at privacy@callwhisperer.app. We may: (a) help facilitate a request with the relevant customer account holder; (b) act on a verified instruction from that customer; and/or (c) handle any data for which Call Whisperer is itself the controller (for example certain service or security logs). We may ask for information needed to verify your identity and to locate relevant records within a specific customer relationship.

We do notoffer a public tool that looks up your number or email across all customers' contact books, and we will not build a cross-tenant "who has my data?" search for third parties.

14. Roles and Legal Bases (UK / EEA)

Where UK GDPR or EU GDPR applies:

• Your account, billing, security, abuse prevention, and product analytics about your use of the Service: Call Whisperer is the controller. We rely on performance of our contract with you and on legitimate interests (for example securing the Service, preventing fraud and abuse, and improving the Service in aggregate), and on legal obligation where applicable.
• Your contact book and third-party business contact data you store or import:you are the controller; Call Whisperer is the processor providing tools at your direction. We do not rely on Call Whisperer's legitimate interests as the basis for your cold outreach or telemarketing.
• Live-call content you generate while using the Service: processed to provide coaching and related features under our contract with you, subject to your responsibility for lawful calling and any notices or consents required from call participants. See also the Live Client Calls terms.

Nothing in this Policy is legal advice to you about your obligations to people you call.

15. Contact Us

If you have questions about this Privacy Policy or your data, please contact us at privacy@callwhisperer.app.