Privacy Notice

Scope and covered individuals

This notice applies globally to three distinct categories of individuals ("data subjects"):

• Customers. The business entities, sole proprietors, or corporate administrators who register an account with Squilling.
• Callers. Any end user who dials a Customer's designated Squilling phone number and interacts with the automated AI phone agent.
• Visitors. Any individual who navigates or browses the public Squilling website.

The jurisdiction-specific supplements near the end apply to people resident in the countries they name, and supersede any conflicting text in the general notice.

Children's privacy and age restrictions

• Platform access restriction. Squilling is a commercial business-to-business (B2B) application. Account creation and platform utilization are strictly restricted to individuals who are at least 18 years of age, or the age of majority in your jurisdiction. We do not knowingly collect, solicit, or maintain personal data from individuals under this age for account management.
• Minor inbound callers. If the Customer targets their business services toward minors, or if an individual under the age of 18 dials the Customer's automated phone agent, the system will process the call audio streams strictly as an automated infrastructure proxy to carry out the Customer's documented instruction, for example booking an appointment or answering a query.
• Parental redress. If you are a parent or legal guardian and discover that your minor child has interacted with a Squilling agent and you wish to review, restrict, or delete that data, contact the specific business entity called, or contact us directly at team@squilling.com. We will act immediately to securely purge the call record upon verification.

Legal roles and accountability

Global data protection laws distinguish between the entity that determines the purposes of data processing (the Data Controller) and the entity that processes data strictly on behalf of another (the Data Processor). Squilling operates in both capacities depending on the dataset:

• Squilling as a Data Controller. We act as the Data Controller for Account Data, Configuration Data, Technical Data, and Billing Data. We independently determine how to process this information to maintain your account, process payments, and ensure platform security.
• Squilling as a Data Processor. We act strictly as a Data Processor, or "Service Provider" under applicable U.S. state privacy laws, for Call Data: voice streams, audio recordings, real-time machine-generated text transcripts, summaries, and caller metadata. The Customer business acts as the sole Data Controller. We process Call Data exclusively under the documented instructions of the Customer, as legally executed via the Data Processing Agreement in section 9 of our Terms of Service.

Note for callers. If you have questions regarding an interaction with a specific business via Squilling, contact that business directly. As the Data Controller, they maintain the primary legal relationship with your data. We still respond to requests sent to us, and we pass on to the Customer anything only they can action.

Categories of information we collect

We collect only the minimum necessary data required to route telephone calls, execute AI interactions, manage third-party integrations, and process service billing.

• Account data. Corporate or business name, administrator names, email addresses, and salted password hashes collected at account registration.
• Call data. Live call audio streams, digital audio recordings, real-time machine-generated text transcripts, automated text summaries, agent action items, and caller identification metadata (ANI/Caller ID numbers).
• Configuration data. Knowledge-base materials, operational documents, price sheets, service lists, operational hours, URL references, and prompt instructions uploaded by the Customer to train and guide the AI agent.
• Integration data. Where a Customer explicitly connects third-party services such as Google Calendar or Microsoft Outlook, we store the OAuth access and refresh tokens and the connected account's email address. We read calendar events to check availability and find appointments, and create or cancel appointments during calls and dashboard tests. We do not store persistent copies of the Customer's broader calendar database.
• Billing data. Pre-paid balance ledgers, transaction records, and consumption metrics. All payment card processing is securely routed through Stripe. Squilling never sees, processes, or stores raw credit card numbers or security codes.
• Technical data. Essential session cookies utilized exclusively for administrator authentication, security verification, and per-call latency performance tracking. We deploy zero third-party advertising, remarketing, or cross-site tracking pixels.

How we utilize your data

Squilling processes personal data strictly for the following operational and lawful purposes:

• Executing the core voice communication service: answering inbound lines, dispensing automated information, routing live traffic, and executing calendar bookings.
• Verifying and authenticating account administrators while maintaining complete database isolation between distinct corporate tenants.
• Computing real-time consumption metrics, managing the pre-paid billing ledger, and triggering automated Stripe account top-ups.
• Dispatching critical transactional and system-level communications, such as low-balance alerts, security alerts, and system notifications. These communications are strictly non-marketing.
• Diagnosing technical infrastructure faults, minimizing voice processing latency, preventing fraudulent usage, and protecting the integrity of the public demonstration environment.
• Satisfying corporate tax, regulatory reporting, and legal accounting obligations.

Absolute data commitments.

• We never sell personal data, call logs, or voice metrics to any third party.
• We never use Customer configuration data, caller audio recordings, or call transcripts to train public, open-source, or foundational machine learning models.
• We never exploit call data for targeted advertising, profile creation, or consumer tracking.

The providers listed under authorized subprocessors handle call data in order to deliver that call.

Google Calendar data and Limited Use

Google Calendar access is optional and starts only when you choose to connect your Google account from the dashboard and authorize Google's consent screen.

• Data accessed and purpose. We use your Google account email to identify the connected account. Calendar event access lets the assistant read event times, titles, and descriptions to check availability and identify a caller's appointments, create requested bookings, and cancel the caller's appointments. Read-only access would not allow booking or cancellation.
• AI processing and sharing. Calendar tool results, including relevant event times and titles, can be sent to the AI service providers listed under authorized subprocessors to answer the caller and perform the requested scheduling task. Spoken responses may also be processed by the configured voice providers. This processing supports the calendar feature you enable; it is not permission to use Google data for unrelated purposes.
• Use restrictions. We do not sell Google user data or use it for advertising, credit scoring, or training, developing, or improving generalized AI or machine learning models. Transfers are limited to providing the authorized user-facing feature with your consent, security purposes, legal obligations, or a business transfer with your explicit prior consent. Human access is limited to the exceptions permitted by Google's Limited Use requirements.
• Storage and protection. Connection credentials and the account email are stored in our application database and accessed through authenticated, tenant-scoped operations. Google API requests use HTTPS. We do not mirror your entire calendar. Relevant calendar information can appear in call transcripts, tool-action logs, or summaries; their retention is described under data retention.
• Disconnecting and deletion. Use Disconnect on the dashboard's calendar card to delete the stored connection credentials and connected email and stop further calendar access through that connection. You can also revoke access from your Google Account. Disconnecting does not delete events already created in Google Calendar or previous call records. Manage those events in Google Calendar; for deletion of data retained by Squilling, contact team@squilling.com.

Squilling's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements, and the Google Workspace API User Data and Developer Policy.

Automated AI interactions and voice recording

Because Squilling functions as an autonomous artificial intelligence voice interaction platform, the following boundaries apply to all operations:

• Automated identity disclosure. Squilling agents do not impersonate human beings. The platform provides a default initialization greeting explicitly informing callers they are speaking to an AI assistant. The Customer bears ultimate responsibility for configuring this disclosure in compliance with local law.
• Audio recording consent. Calls are recorded and transcribed to enable the natural language processing stack to function and to allow Customers to audit operational interactions. The Customer is legally responsible for ensuring that all recording notifications comply with local one-party or all-party wiretapping regulations.
• Human escalation pathways. The AI agent is capable of capturing callback information, flagging priority queries, or forwarding live inbound traffic directly to human operators based on the routing parameters established by the Customer.
• Restricted integration scope. The agent interacts with third-party calendars to check availability and find, create, or cancel caller-requested appointments.

The Legal tab of the customer dashboard contains a ready-written notice that customers can publish on their own site, so their callers are informed before they dial.

Authorized subprocessors and third-party sharing

We do not share data with third-party advertisers. Personal data is disclosed exclusively to vetted technical infrastructure providers ("Subprocessors") contracted to deliver core telephony, AI processing, and infrastructure services.

Depending on your specific back-end agent setup, data may be processed by one or more of the following entities:

Most of these providers are headquartered in the United States and several process data in more than one country. The cross-border data transfers section explains the safeguards.

Note on AI APIs. Our commercial API agreements with these providers explicitly prohibit them from utilizing data transmitted by Squilling to train their proprietary foundational models.

Legal and corporate exemptions. We disclose minimal personal data only when strictly compelled by valid, legally binding government subpoenas, court orders, or law enforcement warrants. We will notify the affected Customer immediately of any such request unless legally prohibited from doing so. In the event of a corporate merger, structural acquisition, or asset sale, data will transition as a core business asset, subject to prior notice to our Customers.

Cross-border data transfers

Squilling is operated from Italy. Because delivering real-time Voice AI requires highly specialized global infrastructure, personal data is routinely transferred across international borders, primarily to data centers located in the United States.

Whenever personal data originating within the European Economic Area (EEA), the United Kingdom (UK), or Switzerland is transferred outside these territories, we enforce legally validated transfer mechanisms, including:

• Adequacy decisions. Relying on formal recognitions by the European Commission, or equivalent UK and Swiss authorities, regarding the data protection safety of the destination country.
• Standard Contractual Clauses (SCCs). Utilizing the European Commission's approved Standard Contractual Clauses, alongside the UK International Data Transfer Addendum and official Swiss modifications where applicable.
• Alternative approved frameworks. Implementing legally approved cross-border data transfer protocols recognized under evolving global privacy frameworks.

Customers acting as Data Controllers remain responsible for ensuring that these global transfer protections align with their unique regional regulatory profiles. Section 9 of the Terms of Service commits us to these safeguards on the Customer's behalf.

You can ask which safeguard applies to a specific transfer by writing to team@squilling.com.

Data retention, purging, and deletion

• Call data lifespan. Call audio files and complete text transcripts are permanently and automatically purged from our active operational storage systems after 90 days.
• Metadata logs. Structural summary call logs, meaning call timestamp, duration, caller ID, and call classification, are maintained continuously to preserve the operational history of active Customer dashboards. This allows a customer to audit past events without us retaining the underlying recordings.
• Account deletion protocols. Upon formal closure or termination of a Customer account, all associated configuration data and registration details are permanently deleted or irreversibly anonymized within standard database cycles.
• Taxation exceptions. Core financial logs and transaction ledger histories are preserved for the strict durations mandated by Italian tax and accounting law. That statutory requirement supersedes any personal or corporate account deletion request.
• Phone number pool. Unused virtual or allocated inbound telephone numbers are automatically revoked and recycled back into the public telephony routing pool 30 days following an account's structured closure or suspension.
• Data export responsibility. Once a Customer copies, downloads, or exports transcripts or call logs into external third-party CRMs, databases, or local drives, that data exits the Squilling data perimeter. The Customer assumes exclusive, independent responsibility for its retention, protection, and compliant deletion.

Security engineering and tenant isolation

We recognize that no digital environment is entirely unbreakable. We design and maintain our infrastructure to maximize resilience, using modern cryptographic standards to prevent unauthorized access or modification.

• Cryptographic password protection. We never store administrative account passwords in plain text. Passwords are irreversibly hashed using PBKDF2-SHA256 at 200,000 iterations combined with a unique, cryptographically secure salt generated per account.
• Strict tenant isolation. Our platform uses a multi-tenant database schema. Every database query, API route, and memory execution is programmatically scoped and filtered by a unique tenant identifier. One customer cannot access, read, or alter another customer's calls, configurations, or logs.
• Session lifetime limits. Access to the customer dashboard requires a secure, authenticated session token that expires 30 days after sign-in. Signing in again issues a fresh token.
• Transit encryption. All communication streams, payloads, and API requests to and from third-party provider environments are encrypted in transit using Transport Layer Security (TLS).
• Public demonstration security. To prevent service degradation and programmatic abuse, our unauthenticated public demo environment enforces a per-IP concurrent call cap, a global concurrent call cap, and a maximum call duration. Demo calls placed over the telephone are additionally limited per originating caller number.
• Data breach protocols. In the event of a verified security incident affecting personal data under our control, we will notify affected Customers without undue delay. This rapid reporting enables our business users to meet their independent legal notification windows. Where Squilling acts as the primary Data Controller, we will immediately report the incident to our lead supervisory authority.

Global privacy rights for all users

Regardless of your geographic location, country of residence, or corporate domicile, Squilling guarantees the following data protection rights. We process all valid requests with zero financial charge:

• Right to access. You may request a structured copy of the personal data Squilling currently maintains about your identity.
• Right to rectification. You can request the immediate correction of inaccurate or incomplete records.
• Right to erasure (deletion). You may ask us to purge records we have no lingering lawful basis to retain, subject to mandatory statutory tax, corporate tracking, or accounting laws.
• Right to restriction. You can request that we freeze active data processing workflows while a pending legal dispute or data accuracy request is verified.
• Right to data portability. You are entitled to receive your raw data in a structured, commonly used, machine-readable digital format.
• Right to object. You may object to data processing activities that rely strictly on our declared "legitimate interests."
• Right to withdraw consent. Where our processing is anchored on your explicit consent, you can revoke that consent at any time. This action will not affect the legality of any processing executed prior to your withdrawal.

Filing a request. To exercise these rights, submit your request to team@squilling.com. We acknowledge requests within a few business days and provide a formal substantive resolution within 30 days, or the shorter timeline dictated by your local laws. To protect consumer privacy, we require identity verification before releasing or modifying records.

Note for callers. To exercise your rights regarding a specific call log, state the name of the business you called and the approximate date and time of the call. Where Squilling acts as a Data Processor, we will securely route your request to the responsible business client and assist them in executing your choice.

Jurisdiction-specific supplements

These localized provisions apply solely to individuals residing within the specified jurisdictions and supersede any conflicting text in the general notice. Everyone keeps the global privacy rights above regardless of where they live.

A. European Economic Area (EEA), United Kingdom, and Switzerland

Lawful bases for processing. Under the EU GDPR, UK GDPR, and Swiss FADP, we process data under four explicit legal structures:

1. Performance of a contract. To deliver the core phone agent software and features you subscribe to.
2. Legal obligation. To satisfy mandatory Italian and European corporate tax codes, financial reporting rules, and accounting laws.
3. Legitimate interests. To protect platform security, enforce anti-abuse rate limits, optimize speech latency, and transmit vital account-level system alerts.
4. Explicit consent. Where you have explicitly opted into a specific processing workflow.

Supervisory authorities. Our lead regulatory authority is the Garante per la protezione dei dati personali (Italy). UK residents retain the right to lodge complaints directly with the Information Commissioner's Office (ICO). Swiss residents can petition the Federal Data Protection and Information Commissioner (FDPIC).

B. United States (state-level consumer privacy frameworks)

This section serves as our comprehensive disclosure under the privacy statutes of California (CCPA/CPRA), Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Tennessee, Indiana, Iowa, Delaware, and New Jersey.

Categories of collected information. Over the preceding 12 months, we have collected: identifiers (account names, emails); commercial information (prepaid credit ledgers, transaction tallies); audio and transcripts (call streams); professional data (business information shared by callers); and electronic network activity (session authentication cookies, latency analytics).

No sale or sharing of data. Squilling does not sell your personal information, nor do we "share" or disclose personal data for cross-context behavioral or targeted advertising. We have never executed such transactions. We do not use or disclose sensitive personal data for purposes other than providing our core services. Consequently, standard "Do Not Sell/Share" opt-out mechanisms have no applicable purpose on our platform.

California rights and Shine the Light. We do not track users across third-party domains; therefore, our platform does not alter its behavior in response to "Do Not Track" or "Global Privacy Control" (GPC) signals. We do not share data with third parties for their independent direct marketing purposes, and we offer no financial incentive or data-monetization programs.

Authorized agents. US residents may use an authorized legal agent to file a rights request. We require signed, written authorization from you proving the agent's legal capacity, and we may verify your identity directly. If we deny a request, you will receive an explicit explanation alongside instructions to file a formal appeal with your State Attorney General.

C. Brazil (LGPD compliance)

In accordance with the Lei Geral de Proteção de Dados (LGPD), we process data based on contractual performance, compliance with legal duties, our legitimate business interests, and consent.

LGPD Article 18 rights. Brazilian residents possess explicit rights to confirm processing, access records, anonymize non-essential data, port data across providers, delete consented datasets, and request a list of our active technical subprocessors.

Data protection officer. Our designated encarregado is reachable at team@squilling.com. Legal petitions may also be submitted to the National Data Protection Authority (ANPD).

D. Canada (PIPEDA and Quebec Law 25)

PIPEDA compliance. We collect, process, and disclose personal data strictly with your informed consent or where authorized by law. You may withdraw consent at any time, subject to contractual restrictions and reasonable notice. Appeals may be sent to the Office of the Privacy Commissioner of Canada (OPC).

Quebec Law 25. The individual designated in charge of the protection of personal information at Squilling is reachable at team@squilling.com. Quebec residents retain unique rights to data portability, de-indexing, unlinking, and data suppression. Formal complaints may be lodged with the Commission d'accès à l'information (CAI).

E. Australia (Privacy Act 1988)

Cross-border disclosures. In accordance with Australian Privacy Principle (APP 8), you acknowledge that the third-party infrastructure subprocessors required to synthesize speech, process language data, and route phone lines are located primarily within the United States.

Grievance resolution. If you believe Squilling has breached the APPs, contact us first at team@squilling.com. If our resolution is unsatisfactory, you may escalate the matter to the Office of the Australian Information Commissioner (OAIC).

F. India (DPDP Act 2023)

Data Principal framework. Under the Digital Personal Data Protection Act, you are recognized as a Data Principal. You hold explicit rights to access a summary of your data, correct inaccuracies, complete pending profiles, request total erasure, withdraw processing consent, and nominate an alternative individual to act on your behalf in the event of incapacity.

Grievance officer. All formal grievances must be routed to team@squilling.com. If you remain unsatisfied with our internal resolution timeline, you maintain the right to lodge an official appeal with the Data Protection Board of India (DPBI).

Complete accountability and contact information

For any inquiries regarding data protection architecture, system subprocessing, or to file an official privacy request, contact us:

• Email: team@squilling.com
• Principal place of business: Milan, Italy

We have not appointed a separate Data Protection Officer, because at our size the law does not require one. The address above is the contact point for everything a DPO would handle, and it reaches the person responsible directly.