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Privacy policy

Version1.0 draft
EffectiveNot yet in force
Applies toUnited Kingdom, United States, Canada
Published byDigiTalker Ltd
StatusAwaiting legal review
On this page
  1. Who we are
  2. Controller and processor
  3. What we collect
  4. Lawful basis
  5. How long we keep it
  6. Who we share it with
  7. International transfers
  8. Your rights
  9. Security
  10. Cookies
  11. Contact

01Who we are

This is a draft, not legal advice. It was written to match how AMD Cop actually works and to cover what carriers and regulators in the UK, the US and Canada ask for. It has not been reviewed by a lawyer and is not in force. Have counsel qualified in each territory review it before you publish it or rely on it in a carrier application.

AMD Cop is answering-machine detection software published by DigiTalker Ltd, a company registered in England and Wales, company number 16279329, VAT GB 487 2019 75. Throughout this policy we means DigiTalker Ltd and you means a visitor to this website or a customer who has licensed the software.

Registered officeUnity House, Fletcher Street, Bolton, England, BL3 6NE
United States office5904 Jessamine St, STE A15, Houston, TX 77081
Contactcontact@digitalker.uk · +44 7468 327682 · +1 917 730 4364

The single most important fact about our data position is this: AMD Cop runs on infrastructure you operate. Call audio is classified in your own environment and never reaches us. We are not a carrier, we do not route your calls, and we do not receive, store or process the personal data of the people your agents ring.

02Controller and processor

For the personal data described in this policy, which is limited to website visitors and customer contacts, we act as the controller.

For call audio and the personal data of called parties, you are the controller and we are neither controller nor processor, because that data never comes into our possession. Classification happens inside your deployment boundary. If you take the vendor-operated deployment described in our terms, that position changes and a separate data processing agreement applies.

Why this matters for a carrier application. Many privacy policies in this industry are written by carriers who do handle call content. Ours cannot copy that language, because a self-managed deployment gives us no access to it.

03What we collect

CategoryWhat it isWhy
Contact detailsName, work email, company, phone if you give it, and what you tell us in the enquiry formTo answer your enquiry and, if you become a customer, to support you
Customer recordsBilling contact, licence and support correspondence To perform the contract and meet our accounting obligations
Website technical dataIP address, browser and device type, pages requested, referring pageTo serve the site, keep it secure and understand which pages are useful
Support diagnosticsLogs or configuration you choose to send us when raising a support caseTo reproduce and resolve the issue

We do not collect call audio, call recordings, dialled numbers, called-party names or any other personal data belonging to the people your campaigns contact. If you send us a recording as part of a support case, treat it as your disclosure, redact it first, and see the retention section below.

04Lawful basis

Where UK or EU GDPR applies we rely on:

05How long we keep it

DataRetention
Enquiries that do not become customers24 months from last contact
Customer recordsDuration of the contract, then 7 years for accounting
Support diagnostics90 days after the case closes
Website technical logs30 days

Anything you deliberately send us for a support case is deleted on the schedule above or sooner on request.

06Who we share it with

We do not sell personal data and we do not share it for cross-context behavioural advertising. We use a small number of processors to run the business, each under a written contract:

To complete before publication. Name each processor, its role and the country it operates from. Regulators in all three territories expect the list to be specific rather than generic, and a carrier reviewing this will look for it.

07International transfers

We operate from the United Kingdom and maintain a United States office in Texas. Where personal data moves outside the UK or the EEA we rely on adequacy regulations where they exist, and on the UK International Data Transfer Addendum or Standard Contractual Clauses where they do not.

This concerns only the limited categories listed above. It does not concern your call audio, which does not move at all.

08Your rights

United Kingdom and European Union

You have the right to access your data, to have it corrected or erased, to restrict or object to processing, to data portability, and to withdraw consent. You may complain to the Information Commissioner's Office at ico.org.uk.

United States

Depending on your state, you may have the right to know what is collected, to delete it, to correct it, to opt out of sale or sharing, and not to be discriminated against for exercising those rights. We do not sell or share personal data as those terms are defined under the CCPA as amended.

Canada

Under PIPEDA you may request access to your personal information and challenge its accuracy. You may complain to the Office of the Privacy Commissioner of Canada.

To exercise any of these, write to the address in the contact section. We respond within 30 days, or one month where UK GDPR applies.

09Security

We apply access controls, encryption in transit, and the principle of least privilege to the limited data we hold. We keep a record of any breach of safeguards involving personal data under our control, as PIPEDA requires, and we notify the relevant regulator and affected individuals where the law requires it.

Security of your own deployment, including the call recordings that stay inside it, is yours to manage. The software is open to inspection so your security team can verify what it does.

10Cookies

This site uses only what is needed to serve the pages. It sets no advertising cookies and runs no cross-site tracking.

To confirm before publication. If you later add analytics, a consent banner becomes mandatory under the UK PECR and the EU ePrivacy Directive, and this section must list each cookie, its purpose and its lifetime.

11Contact

Questions about this policy, or a request to exercise your rights, in writing to:

DigiTalker Ltd
Unity House, Fletcher Street, Bolton, England, BL3 6NE
contact@digitalker.uk

For requests relating to the United States, you may also write to 5904 Jessamine St, STE A15, Houston, TX 77081.

Still to confirm. Whether a Data Protection Officer is required, and a dedicated privacy address rather than the general contact address. Both are questions for counsel and take a sentence each once decided.