Privacy Policy

This Privacy Policy describes how KALLY INTELLIGENCE, INC. ("we", "us", or "our") collects, uses, and protects your personal data when you use our AI-powered phone assistant service KallyAI ("Service").

We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

1. Data Controller

KALLY INTELLIGENCE, INC. is the data controller responsible for your personal data.

2. Data We Collect

2.1 Information You Provide

Data Type	Examples	Purpose
Account Information	Telegram user ID, email (if provided)	Account management, communication
Call Requests	Phone numbers, names, dates, times, task descriptions	Executing calls on your behalf
Payment Information	Processed by Stripe; we don't store card details	Subscription billing

2.2 Information Generated During Service Use

Data Type	Description	Retention
Call Recordings	Audio recordings (with respondent consent)	7 days, encrypted
Transcripts	Text transcriptions of calls	7 days, encrypted
Call Metadata	Duration, status, timestamps	7 days
Usage Logs	Service interactions, errors	30 days

3. Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR Article 6:

• Contract Performance (Art. 6(1)(b)): To provide the Service you requested
• Legitimate Interest (Art. 6(1)(f)): For service improvement, security, and fraud prevention
• Consent (Art. 6(1)(a)): For optional features like marketing communications
• Legal Obligation (Art. 6(1)(c)): For tax records and compliance requirements

4. How We Use Your Data

We use your personal data to:

• Execute phone calls on your behalf
• Provide call transcripts and summaries
• Process payments and manage subscriptions
• Improve the AI's performance and accuracy
• Ensure service security and prevent abuse
• Communicate important service updates
• Comply with legal obligations

5. Data Sharing

We share your data only with:

• Twilio: Telephony provider for making calls
• Stripe: Payment processing
• OpenAI: AI language processing (conversation data is not stored by OpenAI)
• Google Cloud Platform (GCP): Cloud infrastructure provider with data centers in both the European Union and United States

We do NOT sell your personal data to third parties.

6. Data Retention

After retention periods expire, data is automatically and permanently deleted.

7. Data Security

We implement robust security measures:

• Encryption at Rest: All recordings and transcripts are encrypted using AES-256
• Encryption in Transit: All communications use TLS 1.3
• Access Controls: Strict role-based access to data
• Tenant Isolation: Each user's data is cryptographically isolated
• Regular Audits: Security practices are regularly reviewed

8. Your Rights (GDPR)

Under GDPR, you have the following rights:

• Right of Access (Art. 15): Request a copy of your personal data
• Right to Rectification (Art. 16): Correct inaccurate data
• Right to Erasure (Art. 17): Request deletion of your data ("right to be forgotten")
• Right to Restriction (Art. 18): Restrict processing of your data
• Right to Data Portability (Art. 20): Receive your data in a machine-readable format
• Right to Object (Art. 21): Object to processing based on legitimate interest
• Right to Withdraw Consent (Art. 7(3)): Withdraw consent at any time

How to Exercise Your Rights

To exercise any of these rights, contact us at ceo@kallyintelligence.com. We will respond within 30 days.

9. International Data Transfers

KALLY INTELLIGENCE, INC. is a US-based company. Your data may be processed in both the United States and the European Union.

9.1 For EU Users

When your data is transferred from the EU to the US, we ensure adequate protection through:

• EU-US Data Privacy Framework certification (where applicable)
• Standard Contractual Clauses (SCCs) approved by the European Commission
• Technical and organizational safeguards including encryption

9.2 For US Users

Your data is primarily processed in the United States in accordance with applicable US data protection laws.

10. Cookies and Tracking

Our landing page uses the following types of cookies:

10.1 Essential Storage (localStorage)

We use browser localStorage for:

• Cookie Consent Preference: Remembers your consent choice
• User Preferences: UI settings like modal dismissal

These are not cookies but browser storage that stays on your device and is never sent to our servers.

10.2 Analytics Cookies (Consent Required for EU/EEA/UK/CH)

We use Google Analytics 4 (GA4) to understand how visitors use our website. For users in the EU, EEA, UK, and Switzerland, these cookies are only set after you explicitly accept analytics cookies via our consent banner.

Cookie Name	Purpose	Duration
_ga	Distinguishes unique users	2 years
_ga_*	Maintains session state	2 years

GA4 collects anonymized data including: pages visited, time on site, referral source, device type, and general geographic region. This data helps us improve our website and understand user needs.

10.3 Managing Your Cookie Preferences

For EU/EEA/UK/CH users:

• You can accept or reject analytics cookies via the consent banner
• To change your preference, clear your browser's localStorage for this site and refresh the page

For users outside these regions, analytics cookies are loaded automatically as explicit consent is not legally required.

The Telegram bot does not use cookies as it operates within the Telegram platform.

11. Children's Privacy

The Service is not intended for users under 18 years of age. We do not knowingly collect personal data from children.

12. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be notified via email or through the Service. The "Last Updated" date at the top indicates the latest revision.

13. Complaints

If you believe we have violated your data protection rights, you have the right to lodge a complaint with the appropriate authority:

13.1 For EU Users

• Your local data protection authority
• The Spanish Data Protection Agency (AEPD): www.aepd.es — for contact purposes, our EU contact address is in Spain

13.2 For US Users

• The Federal Trade Commission (FTC): www.ftc.gov/complaint
• Your state Attorney General's office

14. Your California Privacy Rights (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with additional rights regarding your personal information:

14.1 Your Rights

• Right to Know: You can request disclosure of the categories and specific pieces of personal information we have collected about you
• Right to Delete: You can request deletion of your personal information, subject to certain exceptions
• Right to Opt-Out: You can opt-out of the "sale" of your personal information. Note: We do NOT sell personal information
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights

14.2 How to Exercise Your Rights

To exercise your California privacy rights, contact us at ceo@kallyintelligence.com with the subject line "CCPA Request". We will verify your identity and respond within 45 days.

14.3 Categories of Information Collected

In the preceding 12 months, we have collected the following categories of personal information:

• Identifiers (Telegram user ID, email if provided)
• Commercial information (subscription and payment history)
• Audio/visual information (call recordings)
• Internet activity (usage logs)

15. Contact Us

For privacy-related questions or concerns:

• Company: KALLY INTELLIGENCE, INC.
• Email: ceo@kallyintelligence.com