Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how Talkif, Inc., a Delaware corporation ("Talkif," "Company," "we," "us," or "our"), collects, uses, discloses, retains, and protects personal information when you use our AI-powered voice calling platform, website, the Talkif apps for iPhone and Mac, APIs, and related services (collectively, the "Service").

This Policy applies to:

Account Holders and Users ("Users"): Individuals and organizations that register for and use the Talkif platform to create, manage, and initiate automated voice calls.
Call Recipients ("Data Subjects"): Individuals who receive voice calls initiated through the Talkif platform by our Users.
Website Visitors: Individuals who visit our website without registering for an account.

By accessing or using the Service, you acknowledge that you have read and understood this Policy. If you are a User, you agree to be bound by this Policy as part of the Terms of Service. If you are a Call Recipient, this Policy informs you of how your data is processed when a Talkif User contacts you through our platform.

2. Data Controller and Contact Information

For purposes of applicable data protection laws (including the EU General Data Protection Regulation, "GDPR"), the data controller depends on the context:

Context	Data Controller	Data Processor
User account data	Talkif	—
Call Recipient data uploaded by a User	The User (our customer)	Talkif
Call Recipient data from inbound calls	Talkif	—
Connector Data (Section 3.5)	The User (our customer)	Talkif
Data sent to apps and AI agents the User connects (Section 3.7)	The User (our customer)	Talkif; the app or agent is a recipient the User chooses
Payment and billing data	Talkif	Stripe (sub-processor)

Company Contact Information:


Legal Entity	Talkif, Inc.
Registered Address	1111B S Governors Ave STE 23788, Dover, DE 19904 US
Privacy Inquiries	privacy@talkif.ai

3. Personal Data We Collect

We collect personal data through the following means: directly from you, automatically through your use of the Service, from third-party authentication providers, and from our Users (in the case of Call Recipients).

3.1 Data You Provide Directly

Category	Data Elements	Purpose	Legal Basis (GDPR)
Identity Data	Full name, email address, phone number	Account creation, authentication, communication	Contract performance (Art. 6(1)(b))
Authentication Data	Password (securely stored), multi-factor authentication credentials; for passkeys, the public key, a sign-in counter, the name you give the passkey and the type of password manager or device that holds it (the private key, and any fingerprint or face data, never leave your device and are never sent to us)	Account security	Contract performance (Art. 6(1)(b))
Organization Data	Company name, tax identification number, registration number, business address	Multi-tenant account management, invoicing	Contract performance (Art. 6(1)(b))
Payment Data	Card brand, last four digits, expiration date (via Stripe; we never receive or store full card numbers)	Payment processing, billing	Contract performance (Art. 6(1)(b))
Contact List Data	Names, phone numbers, email addresses, physical addresses, timezones of individuals to be called	Enabling Users to initiate calls to their contacts	Legitimate interest (Art. 6(1)(f)) / User's legal basis as controller
Call Flow Configuration	AI agent configurations, conversation scripts, prompt templates	Powering automated voice interactions	Contract performance (Art. 6(1)(b))

3.2 Data Collected Automatically

Category	Data Elements	Purpose	Legal Basis (GDPR)
Technical Data	IP address, user agent string, browser type and version, operating system; for the Talkif apps, see Section 3.8	Security monitoring, fraud prevention, service optimization	Legitimate interest (Art. 6(1)(f))
Authentication Events	Login timestamps, IP addresses, authentication method used, success/failure status	Security auditing, abuse detection	Legitimate interest (Art. 6(1)(f))
Usage Data	Last login time, last account access time, feature usage patterns	Service improvement, support	Legitimate interest (Art. 6(1)(f))
Product Analytics Data	Page views, navigation patterns, click interactions, feature adoption events, approximate geolocation (derived from IP at ingestion; raw IP not stored)	Product improvement, feature adoption tracking	Legitimate interest (Art. 6(1)(f))
Session Replay Data	Mouse movement, scrolling behavior, page interactions (all text inputs masked; sensitive fields excluded)	UX debugging, usability improvement	Legitimate interest (Art. 6(1)(f))
Call Metadata	Call direction (inbound/outbound), caller and recipient phone numbers, call duration, call status transitions, timestamps, call identifiers	Service delivery, billing, compliance	Contract performance (Art. 6(1)(b))
Call Recordings	Audio recordings of calls (when enabled by User)	Service delivery per User's configuration	Consent (Art. 6(1)(a)) / User's legal basis as controller
Call Transcripts	Text transcriptions of voice interactions stored in flow execution records	Service delivery, quality monitoring	Contract performance (Art. 6(1)(b))
Call Pickup Data	Push device tokens and availability status for Users who take calls in the app or dashboard	Delivering transferred calls to available Users; notifying the app of an incoming transfer and sending it alerts (Section 3.8)	Contract performance (Art. 6(1)(b))
Diagnostic Data	Error logs, performance traces (with user/account identifiers for correlation)	Service reliability, debugging	Legitimate interest (Art. 6(1)(f))
Security Screening Data	The results of the checks in Section 3.6: your IP address's network, network type (such as a hosting or VPN network) and country; your email domain's mail-server records; your phone number's SMS-fraud risk; the signals found, a risk score and the decision	Fraud and abuse prevention	Legitimate interest (Art. 6(1)(f))

3.3 Data from Third Parties

Source	Data Elements	Purpose
Google OAuth	Google account email, name, profile picture URL, OAuth tokens	Account creation and authentication
Sign in with Apple	Apple's identifier for you, your name (only the first time you sign in), your email address or an Apple private relay address if you choose to hide your email, and an Apple refresh token (stored encrypted, used only to revoke Sign in with Apple when you disconnect Apple or delete your account)	Account creation and authentication
Twilio	Call status updates, call duration, recording URLs, call routing metadata	Call management and billing
Twilio Lookup	Whether a phone number you verify is valid, its SMS-fraud risk score and carrier risk category, and whether the number is blocked (not requested for numbers that start with +1)	Preventing SMS fraud before we send a verification code (Section 3.6)
Stripe	Payment confirmation status, billing address country	Payment processing
Apple App Store	For purchases in the Talkif apps: the signed transaction (identifiers, product, quantity, App Store country, price and currency, the Talkif account it was bought for, test or real purchase) and notices of renewals, refunds and revocations; no Apple Account details	Selling credit packs and plans in the apps; billing (Section 3.8)

3.4 Sensitive Data

We do not intentionally collect sensitive personal data (also known as "special categories" under GDPR Article 9), including but not limited to: racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data for identification, health data, or data concerning sex life or sexual orientation.

However, because our platform facilitates voice calls where Users configure the conversation content, call recordings and transcripts may incidentally contain sensitive information. Talkif does not monitor, analyze, or categorize such incidental sensitive data. Users are responsible for ensuring that their use of call recordings and transcripts complies with applicable laws regarding sensitive data.

3.5 Connector Data

Connectors is an experimental feature. It may change or be withdrawn. See Section 3.6 of the Terms of Service.

A connector is a tool that a User links to their Talkif account so that the User's voice agent can reach it during a call. Examples are the User's own coding assistant sessions, folders of knowledge, and other agents. A connector registers with an API key created in the User's account, or connects through Sign in with Talkif (Section 3.7). An account owner or admin must accept the Connectors terms once before the feature can be used.

What it is. "Connector Data" means:

answers, looked-up facts, task results and progress notes that a connector returns during a call;
the questions and tasks the voice agent sends to a connector;
messages and tasks that the User's connected sessions and connected apps send each other through Talkif, and their progress;
call memory (optional, see below); and
the channel log (see below).

Source. The User's connectors. The User chooses which connectors to link and what they return. Content from the User's machine reaches Talkif only because the User set it up to.

How it is used. What a connector returns is spoken to the caller. The text goes through the language model, speech-to-text and text-to-speech providers already used for the call (Section 5.1) and becomes part of the call transcript and call summary. Before it is spoken, text that looks like a secret (such as a key or password) is removed. This is pattern based and best effort; it does not catch every secret.

Who can reach a connector. The User sets each connector's audience:

Audience	Who can use it on a call
Private or Team	In a personal account, only the owner. In an organization, every owner, admin and member of the organization on a proven call (questions, look-ups and tasks)
Public	Also anyone who calls the account's agent can look things up (lookup only)

In an organization, these people reach all of the organization's connectors, coding sessions included; each question or task tells the connector the asker's profile name. A call is proven when the caller calls from the Talkif app, dashboard or desktop app while signed in, when the call is placed from their own connected session, or when they confirm on their signed-in Talkif app that a call from their phone number is them. A phone number alone never proves who is calling: an unconfirmed phone, embed or API caller reaches at most public connectors.

Between sessions, an organization's owners and admins can reach every connected session and app in it. What other members can do with a session or app follows its sharing setting: private, ask first, or work.

Call memory. Off by default; the User turns it on per Connectors node in a flow. When on, a language model writes a short summary of the owner's past calls with that agent, from the analysis of those calls, and uses it to brief later calls. Talkif chooses the model for this summary from the providers listed in Section 6.1 (Anthropic, or OpenAI if Anthropic is not available). Call memory is stored per call, kept for the account's call content retention period, deleted with the call or the account, and included in data export.

Channel log. Notes of what was asked of or sent to the owner's sessions, and summaries of the owner's calls, delivered to those sessions. Kept for at most 30 days, or for the account's call content retention period if that is shorter. Deleted when the account is deleted or the member is removed, and included in data export.

Who can see it. The owner sees their channel log and call memory in their own sessions. Connector answers spoken on a call appear in that call's transcript and summary, which are visible to the account's users like any other call.

Purpose and legal basis. To provide the Connectors feature the User turned on. Talkif processes Connector Data as processor, on the User's instructions (Section 16 and the DPA). Contract performance (Art. 6(1)(b)) / User's legal basis as controller.

User responsibility. Connectors are a User-directed integration. The User is responsible for what their connectors send to Talkif and to callers. Do not connect a source that holds data you are not allowed to share with Talkif, with its sub-processors, or with the people who can call your agent. Do not make a connector public if it can return personal data or confidential information.

To keep fraud and abuse out of the Service — for example fake sign-ups that make us send verification texts to premium-rate numbers — we check some requests before we carry them out: sign-ups (including with Google and Apple) and requests for a verification text to a phone number. We also limit how many email codes and texts we send.

What we check:

Your email address: whether its domain belongs to a disposable-email service (from a public list of such domains), whether its mail servers exist and where they are hosted (we look up the domain's mail-server records in the public DNS), and whether the same inbox already has an account under a different spelling.
Your IP address: which network it belongs to, whether that is a hosting or VPN network, which country it is in, and whether it is on a public list of networks used for abuse (Spamhaus DROP). We do this with databases we hold ourselves; your IP address is not sent to another company for it.
Your phone number: before we send a verification text to a number that does not start with +1 (the code shared by the United States, Canada and several Caribbean countries), we ask Twilio (Twilio Lookup) whether the number is valid and how likely it is to be used for SMS fraud. We also compare the number's country with your IP address's country.
A bot check: on the sign-up, sign-in and some verification screens, the dashboard runs a Cloudflare Turnstile check in your browser, usually without you noticing. Cloudflare receives your IP address and browser signals to tell people from automated programs.
Our blocklist: email addresses, email domains, phone numbers and number ranges, IP addresses and networks, and mail servers that have been used for abuse.
How often: how many emails and texts were requested for the same address, number, account or IP address in the last hour.

What can happen. Depending on the result, we may refuse a sign-up with a disposable email address, refuse to send a verification text, refuse a request that matches the blocklist, or limit how many codes we send. We send a verification text only after your email address is verified, and add any welcome credit only after your phone number is verified. When an account is used for abuse, our staff can suspend the login and block the email address, phone number and networks involved. From December 9, 2026, they can also remove the unused promotional or bonus credit of an account suspended for abuse (Section 2.6 of the Terms of Service).

Human review. If you think a refusal or a block is a mistake, write to support@talkif.ai and a person will review it.

What we keep:

a record of each screened request (time, IP address, normalized email address, signals found, risk score and decision): 30 days;
Twilio Lookup results: 7 days, stored against a hash of the number;
phone verification attempts (hashed number and IP address): 24 hours; counters of emails and texts sent: 1 hour;
blocklist entries: as long as they are needed to stop the abuse that led to them. When a login is suspended, its email address and phone number are blocked for 30 days.

Legal basis. Our legitimate interest in keeping the Service, its users and the telephone network free of fraud and abuse (GDPR Art. 6(1)(f) and Recital 47).

3.7 Apps and AI Agents You Connect

You can let AI agents and third-party apps work with your Talkif account (Section 3.7 of the Terms of Service):

With an API key, for example an AI assistant using the Talkif MCP server. It can read and change whatever the key's permissions allow, which can include contacts, calls and transcripts.
With "Sign in with Talkif", which connects an app to one account for the person who approves it. A connected app can reach the account's connected sessions (Section 3.5) as that person's role and the sessions' sharing settings allow, and can ring that person in the Talkif dashboard or app for a call with one of the account's voice agents. It receives the questions, tasks and answers exchanged with it, the names of the people who sent them, and the outcome and transcript of the calls it rang. If a webhook address is set for it, we send these events to that address; call transcripts are not sent to a webhook.

Who receives the data. The agents and apps a User connects are recipients the User chooses, not Talkif sub-processors. What they receive is handled under their developer's own terms and privacy policy. For Contact Data, the User remains the controller.

What we keep:

for each connected app: the name and return addresses its developer registered, and when it was created and last used; an app that no account uses is deleted after 24 hours;
for each connection: who connected it, to which account, its label, sharing setting and description, its webhook address and encrypted webhook key, its delivery status, and when it was created, last used and revoked; a revoked connection is deleted after 30 days;
sign-in tokens for connected apps, stored only as a hash: they expire after 1 hour (access) and 30 days (refresh);
events waiting for an app: deleted 1 day after they are delivered or expire; tasks given to sessions and apps, with their progress: deleted 1 week after they finish;
for each API key: when and from which IP address it was last used, daily request and error counts, the number of distinct IP addresses, and up to 50 recent errors, kept while the key exists.

Ending access. A User can disconnect an app at any time under Developer → Integrations. Its access also ends when the person who connected it changes or resets their password, signs out on all devices or leaves the account, and when the account is deleted. API keys can be revoked in the dashboard.

Legal basis. Contract performance (Art. 6(1)(b)); for Contact Data, the User's instructions as controller.

3.8 The Talkif Apps for iPhone and Mac

The Talkif apps for iPhone and Mac come from Apple's App Store (the Mac app from the Mac App Store). They are another way to use the Service, and the rest of this Policy applies to them. This section covers what is different.

Signing in. In the apps, new accounts are created with Sign in with Apple or Google (Section 3.3); existing users can also sign in with their email address and password or a passkey. The apps keep you signed in until you sign out: the Mac app stores your sign-in in the Keychain; the iPhone app keeps its access token in the Keychain and its sign-in cookie (Section 14.1) in the app's own storage.

AI services permission. Before you first use an app, it asks you to allow it to send call audio, transcripts, your messages and contact details to the AI providers that run your agents; the screen names the main ones, and Section 6.1 lists them all. The app cannot be used without it; you can withdraw it in the app's settings, which signs you out. The iPhone app stores your choice on the iPhone. The Mac app records it with your account: the version you agreed to, when, the app and its version, and your IP address.

Notifications (iPhone). The iPhone app receives notifications through Apple's push service:

Call notifications for a call offered to you, such as a transfer or a call a connected session rang you for. They carry identifiers only; the app fetches the details from us when it wakes.
Alerts, according to your notification settings: for example a booking or sale an agent made, something a call left for you to do, a call summary, a campaign that finished or paused, an alert rule that fired, and billing notices such as a low balance. Their text can include agent, campaign, alert-rule and provider names, counts, amounts, dates and your Talkif phone numbers, and for a booking or sale only that the agent made one. They never include the names or phone numbers of the people your agents talked to, or transcripts, summaries or recordings. Other notifications only say "Open Talkif for details".
Agent tasks: when a task between the AI agents and sessions you connected (Sections 3.5 and 3.7) needs you, waits for your review or has a question for you, your iPhone is told, whatever your notification settings. The notice says only that something waits.
"It's me": when a call to one of your account's agents comes from the verified phone number of a member of the account, that member's iPhone can ask "Is this you calling?", with the agent's name, the time and the last four digits of the number called. Confirming needs Face ID, Touch ID or the device passcode; we receive only the answer.

For each device we keep the push token, the app version, an installation identifier, whether notifications are allowed, the language and when the app last checked in (Section 8.1).

Widgets (iPhone). Widgets, also on the Lock Screen, can show your agents and their phone numbers, today's calls with the name or number of the other party, calls that need you, and the balance (only for people who may see billing). This data stays on the iPhone, and on an Apple Watch paired with it that runs the Talkif app, and is deleted when you sign out. Callers' names and the balance are hidden while the iPhone is locked. Calls you take in the app are not added to the iPhone's Recents.

App Attest (iPhone). To keep automated abuse out, the iPhone app can prove that it is a genuine copy using Apple's App Attest when it signs in with a password, resets a password or asks for a verification code. We store the app's attestation key (an identifier, a public key and a counter) and the receipt Apple issued for it; these are not linked to your account. We check the proof ourselves and send nothing to Apple for it.

Purchases through Apple. In the apps, the account owner can buy credit packs and monthly or yearly plans with Apple's In-App Purchase. Apple sells them and processes the payment; a plan is an App Store subscription that Apple renews. Apple does not share the buyer's Apple Account details with us. It sends us each transaction, signed by Apple: its identifiers, the product and quantity, the App Store country, the price and currency, the Talkif account it was bought for, whether it was a test purchase and, for a plan, the period it covers. Apple also tells us about renewals, changes to a renewal, failed renewals, refunds and revocations. For a plan, we also record who confirmed that the account is used for business and which version of the Monthly Plan Terms they accepted. We keep all of this with the billing records (Section 8.1).

Analytics. The iPhone app contains no analytics, crash-reporting or advertising tools. The Mac app sends product analytics to PostHog (Section 14.2): the screens you open and what you click, with all text on the screen masked, your user ID, email address and name, and the platform and app version. It records no sessions and keeps nothing for analytics on your Mac. Advertising measurement (Section 14.4) does not run in the apps.

Updates. The App Store updates the apps. Requests from the apps to our API carry the app's name and version.

Microphone, contacts and your website. The apps use the microphone only for calls. When you import contacts on the iPhone, you pick them in Apple's contact picker and only the people you pick are uploaded; the app cannot read the rest of your address book. If you enter your business website while setting up the iPhone app, the app opens it directly from your iPhone, so that website sees your IP address.

Legal basis. Contract performance (Art. 6(1)(b)); for App Attest and the Mac app's product analytics, our legitimate interest in keeping the Service free of fraud and abuse and in improving it (Art. 6(1)(f)).

4. How We Use Your Data

4.1 Primary Purposes

Purpose	Data Used	Legal Basis (GDPR)
Account provisioning and management	Identity, authentication, organization data	Contract performance
Voice call initiation and routing	Contact phone numbers, call flow configurations	Contract performance
Real-time call processing	Call metadata, transcripts (during active calls)	Contract performance
Connectors (experimental)	Connector Data (Section 3.5)	Contract performance / User's instructions as controller
Apps and AI agents you connect	Data the key or connection allows (Section 3.7)	Contract performance / User's instructions as controller
Talkif assistant	Your messages and the account data the assistant looks up (Section 5.4)	Contract performance / User's instructions as controller
Billing and invoicing	Payment data, call duration, usage metrics	Contract performance
Transactional communications	Email address	Contract performance
Security and fraud prevention	IP addresses, authentication events, technical data, email addresses and phone numbers checked at sign-up and verification, security screening data (Section 3.6)	Legitimate interest
Service reliability and debugging	Diagnostic data, trace identifiers	Legitimate interest
Legal compliance	Billing records, call records, authentication logs	Legal obligation (Art. 6(1)(c))

Purpose	Data Used	Consent Mechanism
AI-powered call analysis	Call transcripts sent to the User's selected LLM provider for post-call insights, summaries, and sentiment analysis	Explicit opt-in per call or account-level setting
Call recording storage	Audio recordings via Twilio	User enables recording in call flow configuration
Website analytics	Pages visited on talkif.ai, how you arrived (including campaign tags), approximate location, device data (see Section 14.3)	Cookie settings, "Analytics" category. Off until you allow it.
Advertising measurement	Whether a visit from one of our ads led to a demo call, contact request, sign-up, first call, phone number or payment, with a hashed email address (see Section 14.4)	On talkif.ai: Cookie settings, "Advertisement" category, off until you allow it. In the Talkif dashboard: in the EU/EEA, the UK, Switzerland and Turkey, a separate, unticked checkbox at sign-up or "Ad measurement" in Settings, off until you allow it; elsewhere, from November 15, 2026, on by default (until then, off until you allow it), and you can switch "Ad measurement" off in Settings at any time.

4.3 Purposes We Do NOT Pursue

We do not use your personal data for:

Selling personal data to third parties
Building advertising audiences from your data: we do not upload customer lists to advertising platforms, create custom or lookalike audiences, or use call content, transcripts or recordings for advertising
Building consumer profiles for sale to data brokers
Training general-purpose AI models (your data is not used to train the AI models of our third-party providers beyond the scope of processing your specific requests)
Credit scoring or automated decision-making with legal effects (unless explicitly agreed in an enterprise contract)

5. AI and Automated Processing Disclosures

5.1 AI-Powered Voice Calls

The core function of Talkif is to enable Users to create and deploy AI-powered automated voice calls. When a call is initiated through our platform:

Large Language Models (LLMs) generate conversational responses in real time based on the User's configured flow and prompts. Conversation context (what the Call Recipient says) is processed by the LLM to generate appropriate responses. Available LLM providers include Anthropic, OpenAI, Google, and xAI. The User selects which provider is used per flow.
Speech-to-Text (STT) services transcribe the Call Recipient's spoken words into text for LLM processing. Available STT providers include Deepgram, Soniox, ElevenLabs, Cartesia, xAI, Amazon Transcribe (AWS), and Google. Some providers receive raw call audio for transcription.
AI decisions. During and after a call, the Service makes automated decisions about the call that its features need: for example whether a person or a voicemail system answered, how the agent handles an interruption and when the Call Recipient has finished speaking, when to end or hold a call or check on a silent Call Recipient, what to do after the call, alerts, and call analysis. For these decisions, call transcript text (short excerpts or the whole transcript) and call metadata are sent to TypeSafe AI, Inc., OpenAI, LLC or Anthropic, PBC, or to the language model the User chose for the flow. No audio is sent. These decisions only steer how the Service behaves; none of them has a legal or similarly significant effect on a Call Recipient. They are part of the Service (the "AI Decision Services" of the DPA).
Text-to-Speech (TTS) services convert the LLM's text responses into synthesized voice audio delivered to the Call Recipient. Available TTS providers include ElevenLabs, Cartesia, xAI, Rime, and Google. The User selects which provider is used per flow.
WhatsApp Business Calling. Where a User enables WhatsApp calling, call signaling (including phone numbers and call events) is exchanged with Meta Platforms, Inc., and call media is carried over Meta's WhatsApp infrastructure between the caller and the Service. WhatsApp calling operates under the User's own WhatsApp Business Account relationship with Meta.
Meta Lead Ads. Where a User connects a Facebook Page, we receive the answers people give in the User's lead forms (such as name, phone number and email address) from Meta Platforms, Inc., add them as contacts and call them as the User configured. We then report each lead's progress to Meta's Conversions API: the lead's identifier, its stage, and the call analysis outcome, confidence, reasoning and suggested next step. This runs under the User's own relationship with Meta, as a recipient the User chooses (Section 6.1).

Call Recipients are interacting with an AI system, not a human, unless and until the User transfers the call to a person. Users of the Talkif platform are responsible for disclosing this fact to Call Recipients in compliance with applicable law, including but not limited to the EU AI Act, US state AI disclosure laws, and Turkish regulations.

5.2 AI Call Analysis (Opt-In)

When a User enables AI-powered call analysis:

Call transcripts are transmitted to the User's selected LLM provider via API for processing.
Analysis may include: call summaries, sentiment detection, key topic extraction, and action item identification.
All LLM providers process API data under their respective terms; API data is not used for model training. xAI retains API inputs and outputs for up to 30 days, then auto-deletes.
Analysis results are stored in the User's account and are accessible only to the User.

5.3 Automated Decision-Making

Talkif employs the following automated decision-making processes:

Process	Description	Human Override
Call queue prioritization	When an Account is at its concurrent call limit, waiting calls are ordered by call direction (inbound calls first), how the call was created (direct, scheduled, or campaign), any priority the User assigned to the call or contact, and time spent waiting. Ordering does not depend on a service tier or on any characteristic of the Call Recipient.	No individual decisions about Call Recipients; affects call ordering only.
Rate limiting	Automated throttling of call volume per Account based on the Account's limits (the same defaults for every Account) and overall system capacity.	Users can contact support to adjust limits.
Balance-based campaign pausing	Campaigns are automatically paused when account balance drops below threshold.	Users can add funds to resume.
Fraud detection	Authentication events are monitored for suspicious patterns (e.g., multiple failed logins). Sign-ups and requests for verification texts are screened, email codes and texts are rate-limited, and a request may be refused automatically, for example a sign-up with a disposable email address or a verification text to a number at high risk of SMS fraud (Section 3.6).	Write to support@talkif.ai and a person reviews the decision.
AI decisions during and after calls	Automated decisions about a call that steer how the Service behaves (Section 5.1), for example when the agent stops speaking or a call ends.	No individual decisions with legal or similarly significant effects on a Call Recipient; they affect the conduct of the call only.

We do not engage in automated decision-making that produces legal effects or similarly significant effects on individuals solely through automated means, as contemplated by GDPR Article 22, except as described above.

5.4 Talkif Assistant

The assistant in the Talkif dashboard answers questions about your account and drafts or changes flows when you ask it to. To do this, it sends your messages, the page you are on, and the account data it looks up — for example flows, phone numbers, contacts, call details and transcripts, campaigns and balance — to Anthropic, PBC. When you ask it to look into a business's website, it fetches that site and searches the web through Anthropic. The assistant only proposes changes; nothing changes until you confirm it. Your conversations are kept until your login or the account is deleted. Legal basis: contract performance (Art. 6(1)(b)); for Contact Data, the User's instructions as controller.

We share personal data with the following categories of recipients, solely for the purposes described in this Policy.

6.1 Sub-Processors (Service Providers)

Sub-Processor	Data Shared	Purpose	Processing Location(s)
Twilio, Inc.	Phone numbers, call metadata, call audio, call audio of the person a call is transferred to by phone; phone numbers you verify	Voice telephony, SMS, transfers to phone numbers; SMS-fraud checks before a verification text (Twilio Lookup)	USA, Ireland, Australia
Stripe, Inc.	Email address, payment tokens, billing address, transaction amounts	Payment processing	USA, Ireland, India
Anthropic, PBC	Call transcripts, user prompts, conversation context; call metadata for AI decisions; messages to the Talkif assistant and the account data it looks up	LLM conversation processing, call analysis, call memory for Connectors, AI decisions, the Talkif assistant (Section 5.4)	USA, Europe, Asia, Australia
OpenAI, LLC	Call transcripts, user prompts; call metadata for AI decisions	LLM conversation processing, call analysis; call memory for Connectors (when Anthropic is not available); AI decisions	USA, EU
Google LLC	Call transcripts, user prompts, text content for speech synthesis, raw call audio, OAuth authorization codes	LLM, TTS, STT, OAuth authentication	USA, EU, Asia (30+ regions)
xAI Corp.	Call transcripts, user prompts, raw call audio (STT), synthesized speech (TTS)	LLM conversation processing, call analysis, STT, TTS	USA, EU
ElevenLabs, Inc.	Text content for speech synthesis, raw call audio	Text-to-Speech, Speech-to-Text	USA, EU
Cartesia AI, Inc.	Text content for speech synthesis, raw call audio	Text-to-Speech, Speech-to-Text	USA
Deepgram, Inc.	Raw call audio	Speech-to-Text	USA, EU
Soniox, Inc.	Raw call audio	Speech-to-Text	USA, EU, Japan
Rime Labs, Inc.	Text content for speech synthesis, generated speech audio	Text-to-Speech	USA
TypeSafe AI, Inc.	Call transcript text (excerpts or the whole transcript) and call metadata (no audio)	AI decisions (including voicemail detection)	USA
Meta Platforms, Inc.	Phone numbers, call signaling and metadata, call media over WhatsApp infrastructure	WhatsApp Business Calling (when enabled by User)	Global (Meta infrastructure)
Cloudflare, Inc.	Call audio (encrypted DTLS-SRTP between our media relay and the user's device; Cloudflare cannot decrypt it), IP addresses of browsers and phones; for the bot check, IP address and browser signals	Relaying call audio to people who take calls in the dashboard or app, and for web calls (TURN); bot checks at sign-up, sign-in and verification (Turnstile)	Global (Cloudflare network)
Resend, Inc.	Email addresses, email content	Transactional email delivery	USA
Apple Inc.	Push device tokens; for call notifications, identifiers only; for alerts, the notification text (agent, campaign and alert-rule names, amounts and your Talkif phone numbers; never the names or numbers of the people your agents talked to, or call content); for Sign in with Apple, the authorization code and refresh token exchanged with Apple	Notifications to the Talkif iPhone app (Apple Push Notification service, Section 3.8); Sign in with Apple	USA
Better Stack, Inc.	Application logs, error data, performance metrics (PII redacted)	Error monitoring, uptime monitoring	EU (Frankfurt)
PostHog, Inc.	Usage data, session recordings (inputs masked), user identity, device metadata, approximate geolocation (raw IP not stored)	Product analytics, UX debugging, feature adoption tracking	EU (Frankfurt)
Amazon Web Services, Inc. (AWS)	All data (encrypted in transit); raw call audio when a flow uses Amazon Transcribe	Cloud hosting, compute, storage, networking; Speech-to-Text (Amazon Transcribe)	USA, EU

Note: LLM, TTS, and STT providers are configurable per flow. A single call uses one LLM provider, one TTS provider, and one STT provider, selected by the User in their flow configuration. Not all sub-processors receive data for every call.

Connectors (Section 3.5) do not add a sub-processor. Connector Data is processed by the language model, speech-to-text and text-to-speech providers already listed above, and stored on AWS.

Apps and AI agents you connect (Section 3.7) are not sub-processors: they are recipients the User chooses.

Apple Inc. sells purchases made in the Talkif apps and runs App Attest on the device as an independent controller, under its own terms and privacy policy (Section 3.8).

When a User enters their own third-party AI provider key, uses their own Twilio account or SIP provider, or connects their own Meta account for Meta Lead Ads (Section 5.1), the User contracts with that provider directly; we exchange data with it on the User's instructions, and it is not a Talkif sub-processor.

Cloudflare, Inc. and Apple Inc.: Added 2026-10-02. Under Section 7.4 of the DPA these take effect for production customer data on 2026-11-01.

TypeSafe AI, Inc.: Added 2026-10-04. Under Section 7.4 of the DPA it takes effect for production customer data on 2026-11-03.

AI decisions: Added 2026-10-31 (Section 5.1) and in effect from that date for all accounts; TypeSafe AI, Inc. was listed for voicemail detection only before.

Connectors: Connector Data (Section 3.5) added 2026-10-16. No new sub-processor. Takes effect 2026-11-15.

Security screening, connected apps, the Talkif assistant and Meta Lead Ads: described 2026-11-09 (Sections 3.6, 3.7, 5.1 and 5.4). No new sub-processor.

Talkif apps for iPhone and Mac: described 2026-11-11 (Section 3.8). No new sub-processor; Apple's push purpose includes alerts to the iPhone app.

6.2 Disclosures Required by Law

We may disclose personal data to law enforcement, regulatory authorities, courts, or other governmental bodies when required by applicable law, legal process, or governmental request, including:

Responding to valid subpoenas, court orders, or search warrants
Complying with regulatory investigations
Protecting the rights, property, or safety of Talkif, our Users, or the public
Enforcing our Terms of Service

Customer Notification. Where legally permitted, we will notify affected Users before disclosing their data in response to legal process. We will limit disclosure to the minimum extent necessary and strictly for the required purpose.

Objection to Improper Requests. Talkif will object to information requests that we reasonably believe were not issued properly or that are overly broad. We will seek to narrow the scope of any request to the minimum data necessary to satisfy the legal obligation.

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, personal data may be transferred to the successor entity. We will notify affected Users of any such transfer and any changes to this Policy resulting from it.

6.4 No Sale of Personal Data

We do not sell personal data. We do not participate in data broker networks, and we do not give advertising platforms customer lists, call content, transcripts or recordings.

The advertising measurement described in Section 14.4 sends advertising platforms a record that a visit from one of their ads led to an action on our website or in the Service. Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), this may count as "sharing" personal information for cross-context behavioral advertising. On talkif.ai it happens only after you allow the "Advertisement" category in Cookie settings. In the Talkif dashboard it is off until you allow it in the EU/EEA, the UK, Switzerland and Turkey, and, from November 15, 2026, on by default elsewhere (until then, off until you allow it everywhere). You can switch "Ad measurement" off in Settings at any time, and we treat a Global Privacy Control (GPC) signal from your browser as a request to opt out (Section 11.3).

7. International Data Transfers

Talkif is a United States-based company. If you are located outside the United States, including in the European Economic Area ("EEA"), United Kingdom ("UK"), Switzerland, or Turkey, your personal data will be transferred to and processed in the United States and potentially other countries where our sub-processors operate.

7.1 Transfer Mechanisms

For transfers of personal data from the EEA, UK, or Switzerland to the United States or other countries not recognized as providing an adequate level of data protection, we rely on the following legal mechanisms:

Standard Contractual Clauses (SCCs): We enter into the European Commission's Standard Contractual Clauses (as approved by Commission Implementing Decision (EU) 2021/914) with our customers (where we act as processor) and with our sub-processors.
UK International Data Transfer Addendum: For transfers from the United Kingdom, we rely on the UK Addendum to the EU SCCs (as approved by the UK Information Commissioner's Office) or the UK International Data Transfer Agreement (IDTA), as applicable.
EU-US Data Privacy Framework (DPF): Where our sub-processors are certified under the EU-US Data Privacy Framework, such certification serves as an additional transfer mechanism for data transferred to those recipients in the United States.
Supplementary Measures: We implement technical and organizational measures to supplement the above mechanisms, including encryption in transit (TLS 1.2+) and at rest, access controls, and pseudonymization where feasible.

7.2 Transfer to Turkey

For personal data transfers to or from Turkey, we comply with the requirements of Law No. 6698 on the Protection of Personal Data ("KVKK"), including obtaining necessary approvals from the Turkish Personal Data Protection Authority ("KVKK Board") or relying on permitted exceptions under KVKK Article 9.

8. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.

8.1 Retention Schedules

Data Category	Retention Period	Rationale
User account data	Until account deletion is requested, plus 7-day grace period	Contract performance; enable account recovery
Authentication credentials	Duration of account existence. Passkeys are removed when you delete them or close your account. The Apple refresh token is revoked at Apple and deleted when you disconnect Apple or close your account.	Account security
Session tokens	Limited lifetime with automatic rotation	Session management; security
Billing and financial records	7 years from transaction date, or as required by applicable tax law	Legal/tax compliance (tax record-keeping, VAT, payment reconciliation, regulatory audits)
Caller identity (phone numbers)	Configurable per account (30–3,650 days), default 1,825 days (5 years). When the period expires, the calling and called numbers are scrubbed; the remaining call record (duration, cost, timestamps, outcome) is preserved for billing and analytics.	Defence of legal claims (GDPR Art. 17(3)(e)) — the number is the only evidence that a specific call was placed with consent. The default is set by the longest applicable limitation period in the jurisdictions we operate in: the four-year federal statute of limitations for TCPA claims (28 U.S.C. § 1658), the five-year FCC internal do-not-call honour period (47 C.F.R. § 64.1200(d)), and the three-year retention required by the CRTC Unsolicited Telecommunications Rules. Also: billing reconciliation and dispute resolution.
Call content (transcripts, AI analysis, insights)	Configurable per account (7–3,650 days), default 90 days. Scrubbed independently of, and normally long before, caller identity.	Data minimisation. No legal obligation requires retaining conversation content, and in jurisdictions requiring all-party recording consent, retaining it enlarges risk rather than reducing it — so it is held only as long as needed for quality review and dispute handling.
Call recordings	Configurable per account (7–365 days; default 90 days). Recordings are permanently deleted from storage after the retention period expires.	Per User configuration; regulatory requirements vary by jurisdiction
Contact list data	Until account deletion or User-initiated removal, plus up to 90 days until permanent purge	Service delivery per User instruction
Phone verification codes	10 minutes	One-time use; security
Transient event data	7 days	Event processing
Cache data	Short-lived, depending on type	Performance optimization
Authentication event logs	As required by applicable law	Security auditing, compliance
Diagnostic and trace data	30–90 days	Debugging, observability
Security screening records (Section 3.6)	30 days	Fraud and abuse prevention
Twilio Lookup results	7 days	Not checking the same number again
Phone verification attempts; email and text counters	24 hours; 1 hour	Rate limiting
Blocklist entries	As long as needed to stop the abuse that led to them; 30 days for the email address and phone number of a suspended login	Fraud and abuse prevention
Connected apps and their connections (Section 3.7)	While connected; revoked connections are deleted after 30 days and unused apps after 24 hours; tokens expire after 1 hour (access) and 30 days (refresh)	Providing the connection; security
Events and tasks for sessions and apps	Events: 1 day after delivery or expiry; tasks: 1 week after they finish	Delivering them
Talkif assistant conversations	Until your login or the account is deleted	Showing your conversation history
Connector Data in calls (answers, task results, progress notes spoken on a call)	Part of the call transcript and summary; follows the call content period above	Same as call content
Call memory (Connectors, optional)	Kept for the account's call content period; deleted with the call or the account	Briefing later calls; data minimisation
Channel log (Connectors)	At most 30 days, or the account's call content period if shorter; deleted on account deletion or member removal	Delivering notes to the owner's sessions
Data exports	24 hours after generation	Data portability; minimize data exposure
Push device tokens (Call Pickup Data)	Until you sign out of the Talkif app on that device or another user signs in to the app on it. When Apple reports a token as no longer valid, nothing more is sent to it. A device that has not opened the app for 30 days no longer receives notifications, and its record is deleted 90 days after the app last checked in.	Delivering calls and alerts to your phone
AI services permission (Talkif apps)	On the iPhone: stored on the device. In the Mac app: the record with your account is kept while your login exists and, after it is deleted, for as long as a claim about that choice could be brought	Showing which version you agreed to and when
Purchase records (Talkif apps)	Kept with billing and financial records (7 years)	Tax and accounting; refunds
App Attest keys (iPhone app)	While the app installation uses them	Checking that requests come from a genuine app
Availability status (Call Pickup Data)	Live availability from an open dashboard or app expires 45 seconds after its last signal, or immediately when you switch it off. The "Available for calls" setting for the mobile app is kept until you change it.	Offering transferred calls only to people who are available

Retention ordering. The three call-related periods are enforced in a fixed order: caller identity ≥ call content ≥ call recordings. Content that outlived the identity it belongs to could not be attributed or acted upon, and a recording that outlived the record pointing to it could not be located or deleted on request. This ordering is enforced by the system, not merely presented as a recommendation in the settings interface.

8.2 Soft Deletion and Data Persistence

When a User requests account deletion:

A confirmation email is sent to the account owner.
A 7-day grace period begins, during which the deletion can be cancelled. During it the account is read-only: its agents take no calls, schedules and campaigns do not run, connected apps lose access, and nothing can be changed except cancelling the deletion or requesting a data export.
After the grace period, the account and all associated operational data (calls, flows, contacts, phone numbers, schedules, campaigns) are removed from application access and excluded from all queries and interfaces. If the account has an unpaid or disputed charge, an open payment dispute, or a balance hold for a call in progress, the deletion waits until it is resolved, and the account stays read-only until then.
Billing and financial records are retained for 7 years from the transaction date (or as required by applicable tax law) to comply with legal and regulatory obligations.
External resources are cleaned up: phone numbers rented from Talkif are released (one already suspended for unpaid rent is released on the schedule in Section 5.11 of the Terms of Service); numbers in the User's own Twilio account stay there and only our call settings are removed from them; our routing for numbers from the User's SIP provider is removed; API keys and connected apps stop working.
Permanent deletion: operational data removed from application access is permanently purged from our systems within 90 days of the account deletion date. Billing records are permanently purged after the applicable legal retention period expires.

During the period between removal from application access and permanent purge, data is inaccessible through any application interface but may exist in database backups. Backups are retained for 30 days and rotated automatically, ensuring complete purge from backups within 30 days of data being removed from the live database.

The workspace created with your login. If you delete the personal workspace that was created when you signed up, your login goes with it: when the deletion runs, your sign-in sessions, passkeys and Google / Apple sign-in are removed, and at the permanent purge your name, email address, phone number and password are erased from our user records, even if you also belong to other organizations.

Deleting an account (Section 8.2) removes a workspace. You can also delete your login itself, which removes you as a Talkif user, including when you only belong to someone else's organization:

In your security settings, choose to delete your login and confirm it is you with your password, your two-factor code, or a code we email you.
You cannot start it while you own an organization that has other members and no other owner (hand the ownership to someone first), or while a workspace that would be deleted with you has an unpaid or disputed charge, or a balance hold for a call in progress.
Your own workspaces, and organizations whose only member is you, are deleted with your login exactly as in Section 8.2. They become read-only from the moment you confirm. Organizations that have other members are not deleted; what you created in them stays with that organization.
A 7-day grace period follows. You can still sign in, and you can cancel at any time until the deletion runs.
When it runs, you are removed from every organization and signed out on every device; your password, passkeys, two-factor secrets and Google / Apple sign-in are removed (Apple's token is revoked at Apple); your devices for call notifications, your availability status, the apps you connected, your assistant conversations and your sign-in history are deleted; and your name, email address and phone number are erased from our user records. Billing records are kept as described in Section 8.2. We keep a record that the deletion happened and when, without your personal data.
If something that blocks the deletion appears during the grace period (for example, an organization you own gains members), nothing is deleted: we email you, and you can resolve it or cancel.

9. Data Security

We implement technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction.

9.1 Technical Measures

Measure	Implementation
Encryption in transit	TLS 1.2+ for all communications
Encryption at rest	Provided through our cloud infrastructure provider's storage encryption
Password hashing	Industry-standard adaptive hashing with per-user salts
Authentication tokens	Cryptographically signed tokens with short expiration and automatic rotation
Multi-factor authentication	TOTP-based second factor with one-time backup codes; passkeys (FIDO2/WebAuthn), which prove possession of your device plus a fingerprint, face or device PIN check performed on the device
API security	Secure API validation and query practices
Account isolation	All data queries scoped by account; enforced at application layer
Rate limiting	Per-account and per-endpoint rate limiting to prevent abuse

9.2 Organizational Measures

Measure	Description
Access controls	Role-based access (Owner, Admin, Member) with principle of least privilege
Security auditing	Authentication events logged with IP, user agent, and timestamp

9.3 Breach Notification

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of natural persons:

GDPR: We will notify the relevant supervisory authority within 72 hours of becoming aware of the breach (GDPR Article 33). Where the breach is likely to result in a high risk, we will notify affected data subjects without undue delay (GDPR Article 34).
CCPA/CPRA: We will notify affected California residents in accordance with California Civil Code Section 1798.82.
KVKK: We will notify the Turkish Personal Data Protection Authority and affected data subjects "as soon as possible" (KVKK Article 12(5)).

If you are located in the EEA, UK, or Switzerland, you have the following rights under the GDPR (or UK GDPR / Swiss FADP):

Right	Description	How to Exercise	Status
Right of access (Art. 15)	Obtain confirmation of whether we process your data and receive a copy	Contact privacy@talkif.ai	Available
Right to rectification (Art. 16)	Correct inaccurate personal data	Update via account settings or contact us	Available
Right to erasure (Art. 17)	Request deletion of your personal data	Account deletion flow in settings (24h confirmation + 7-day grace period); deleting your own login in security settings (Section 8.3, 7-day grace period)	Available, subject to the exceptions in Art. 17(3) — see "Limits on erasure" below
Right to restriction (Art. 18)	Restrict processing of your data in certain circumstances	Contact privacy@talkif.ai	On request (no self-service mechanism)
Right to data portability (Art. 20)	Receive your data in a structured, machine-readable format	Settings > Data Export (JSON format, email-confirmed, 24h download window)	Available
Right to object (Art. 21)	Object to processing based on legitimate interest or direct marketing	Contact privacy@talkif.ai	On request (no self-service mechanism)
Right not to be subject to automated decision-making (Art. 22)	Not be subject to decisions based solely on automated processing with legal or significant effects	Contact privacy@talkif.ai	See Section 5.3
Right to withdraw consent (Art. 7(3))	Withdraw consent at any time where processing is based on consent	Disable AI analysis in settings; contact us for other consent-based processing	Available for AI analysis

Limits on erasure (Art. 17(3)):

Article 17(3) removes the right to erasure where continued processing is necessary for compliance with a legal obligation (Art. 17(3)(b)) or for the establishment, exercise or defence of legal claims (Art. 17(3)(e)). We rely on those exceptions in two situations, and we state them here in advance so that a refusal is never a surprise:

Billing and financial records are kept for 7 years from the transaction date under tax and accounting law, and cannot be erased on request.
The calling and called telephone numbers of a call, together with the record of the consent relied on for that call, are kept for the applicable limitation period — by default 5 years — because that record is the only means by which either we or our User can answer a claim that the call was placed unlawfully. Erasing it during the limitation period would destroy the evidence needed to respond to the very claim you may bring.

These exceptions are limited to the specific data described above. Everything else associated with the call — the recording, the transcript, and any AI analysis of it — is erased on request, and is in any event deleted automatically on the much shorter schedules set out in Section 8.1. Where we decline erasure we will tell you which exception applies, what it covers, and when the period ends.

Exercising Your Rights:

Email: privacy@talkif.ai
We will respond within 30 days (extendable by 60 days for complex requests, with notification).
We may request identity verification before processing your request.
These rights are not absolute and may be subject to legal exceptions — see "Limits on erasure" above.

Right to Lodge a Complaint:

You have the right to lodge a complaint with your local supervisory authority. A list of EEA supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

11. Your Rights Under CCPA/CPRA (California Residents)

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

11.1 Categories of Personal Information Collected

CCPA Category	Examples	Collected	Source
A. Identifiers	Name, email, phone number, IP address, account ID; push device tokens and app installation identifiers (Talkif apps)	Yes	You, automatically
B. Customer records	Name, phone, address, payment card info (last 4 digits)	Yes	You, Stripe
C. Protected classifications	Not intentionally collected	No	—
D. Commercial information	Billing history, call usage, Account balance and top-up history	Yes	Automatically
E. Biometric information	Voice recordings processed for transcription only, not for biometric identification. See Category H (Sensory data).	No (not used for identification)	—
F. Internet/network activity	Login history, feature usage, user agent, page views, click events, session recordings; website analytics and advertising measurement events, under the conditions in Sections 14.3 and 14.4	Yes	Automatically
G. Geolocation data	Timezone, approximate location via IP	Yes	Automatically
H. Sensory data	Call recordings (when enabled), AI-generated voice audio	Yes (opt-in)	Service operation
I. Professional/employment info	Company name, role, tax ID	Yes	You
J. Education information	Not collected	No	—
K. Inferences	AI call analysis results (opt-in): sentiment, summaries	Yes (opt-in)	Derived from call data
L. Sensitive personal information	Account credentials, phone numbers used for calls	Yes	You

11.2 Business Purposes for Collection

We collect and use personal information for the following business purposes:

Providing the Service (account management, call processing, billing)
Security and fraud prevention
Debugging and service reliability
Legal compliance
Service improvement (aggregate, de-identified analytics only)

11.3 Your CCPA/CPRA Rights

Right	Description
Right to know	Request disclosure of the categories and specific pieces of personal information we have collected
Right to delete	Request deletion of personal information (subject to exceptions)
Right to correct	Request correction of inaccurate personal information
Right to opt-out of sale/sharing	We do not sell personal information. Advertising measurement (Section 14.4) may count as sharing. Opt out at any time with "Cookie settings" on our website or the "Ad measurement" setting in the Service; a Global Privacy Control (GPC) signal is honored as an opt-out
Right to limit use of sensitive personal information	Request limitation of use of sensitive personal information to service-necessary purposes
Right to non-discrimination	We will not discriminate against you for exercising your rights

11.4 How to Exercise Your Rights

Email: privacy@talkif.ai

We will verify your identity before processing a request by matching the request to your account information. We will respond within 45 days (extendable by an additional 45 days with notification).

Authorized Agents: You may designate an authorized agent to make a request on your behalf. We may require the agent to provide proof of authorization and may separately verify your identity.

11.5 California "Shine the Light"

California Civil Code Section 1798.83 permits California residents to request information about disclosure of personal information to third parties for direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

11.6 Financial Incentive Programs

We do not offer financial incentives related to the collection, sale, or deletion of personal information.

12. Your Rights Under KVKK (Turkish Residents)

If you are a resident of Turkey, you have the following rights under Law No. 6698 on the Protection of Personal Data ("KVKK"):

12.1 Rights of Data Subjects (KVKK Article 11)

You have the right to:

Learn whether your personal data is being processed.
Request information about the processing if your data has been processed.
Learn the purpose of processing and whether data is being used for its intended purpose.
Know the third parties to whom your personal data has been transferred, domestically or abroad.
Request rectification of incomplete or inaccurate personal data.
Request deletion or destruction of personal data under the conditions set forth in KVKK Article 7.
Request notification of rectification or deletion to third parties to whom your data has been transferred.
Object to a result that is exclusively against your interests and that was reached through analysis of your processed data by automated systems.
Claim compensation for damages arising from unlawful processing of your personal data.

12.2 Data Transfer Abroad

Your personal data will be transferred to the United States for processing. This transfer is carried out in accordance with KVKK Article 9, based on:

Explicit consent of the data subject, supplemented by appropriate contractual safeguards

12.3 How to Exercise Your Rights

You may submit requests regarding your KVKK rights to:

Email: privacy@talkif.ai
Written petition to our registered address (notarized signature or registered email ("KEP") required for written applications)

We will respond within 30 days from receipt of your request.

13. Call Recording and Telecommunications Disclosures

13.1 Call Recording

Talkif enables Users to record voice calls through our platform. A recording covers the entire call, including any part after the call is transferred to a person, until the call ends. Users are solely responsible for complying with all applicable call recording laws, including federal and state wiretap laws, the EU ePrivacy Directive, KVKK, and any other applicable regulations. Requirements vary by jurisdiction — some require all-party consent for recording. See our Acceptable Use Policy for detailed guidance on call recording compliance.

13.2 AI Voice Disclosure

Calls made through Talkif use AI-generated voices. Multiple jurisdictions — including under the EU AI Act, US state laws, and FTC rules — require disclosure that a call recipient is speaking with an automated system. Users are responsible for ensuring appropriate AI disclosure at the beginning of each call. See our Acceptable Use Policy for detailed AI disclosure requirements.

13.3 Automated Calling Compliance

Automated and AI-voiced calling is regulated in nearly every jurisdiction (for example, the TCPA in the United States and the ePrivacy rules in the EU). Because Talkif enables automated AI-powered calling:

Users must obtain the consent required by each Call Recipient's jurisdiction (including any heightened written-consent standard for marketing calls) before using the Service to contact them.
Users must maintain their own Do Not Call lists and comply with applicable do-not-call registries.
Users must not use the Service to place unsolicited marketing calls.
Talkif provides tools for managing contact lists, but does not verify that Users have obtained required consent.

Talkif is a technology platform. The User, as the initiator of calls, bears full responsibility for calling compliance. See our Communications Compliance Addendum, Acceptable Use Policy, and Terms of Service for details.

13.4 Website Demo Calls

The demo calls on talkif.ai, including those in our blog, are run by Talkif for its own website. For these calls Talkif is the controller of your personal data, not a User.

What we process: your voice during the call, a transcript of what you and the agent say, call details (date, time and duration), and your IP address and browser details.
How it is processed: your voice is processed in real time by our speech-to-text, language-model and text-to-speech providers (Section 6.1) so that the agent can talk with you. Before the call starts, an invisible Cloudflare Turnstile check helps keep automated abuse out.
Recording: every demo call is recorded and transcribed. We use the recordings and transcripts to run and check the demo, to improve it, and to detect abuse. We do not use them for advertising or to train general-purpose AI models (Section 4.3).
Notice and legal basis: we tell you that the call is recorded before you start it, and starting the call is your consent to the recording (GDPR Art. 6(1)(a); KVKK Art. 5(1)). You can end the call at any time; ending it stops the recording.
Retention: recordings and transcripts are deleted automatically 90 days after the call.
Your rights: to have a demo call deleted sooner, or to exercise any other right in Sections 10 to 12, write to privacy@talkif.ai with the date and approximate time of the call so that we can find it.

14. Cookies and Tracking Technologies

14.1 Current Usage

The Talkif platform uses the following cookies and tracking technologies.

The Talkif dashboard sets no analytics or advertising cookies of its own. The only cookies it relies on are strictly necessary ones: the sign-in cookie, and Stripe's fraud-prevention cookies when you add a card or pay. Whether advertising measurement runs in the dashboard depends on your choice and your region (Section 14.4).

Technology	Type	Purpose	Duration
Sign-in cookie	Strictly necessary first-party cookie, set by the Talkif API (not readable by page scripts)	Keeps you signed in by renewing your short-lived access token	7 days; replaced each time it is used
Access token	Browser storage (Talkif dashboard), sent in a request header	Authenticates your requests to the API	Short-lived; removed when you sign out
Dashboard working data	Browser storage (Talkif dashboard; app storage in the Mac app)	What the dashboard needs to work as you use it: one-time checks for passkey, Google, Apple and Meta sign-in flows, the page to return to after checkout, your light/dark theme, notices you dismissed and your assistant chat state. Never used for analytics or advertising.	Until you sign out, the flow ends, or you clear your browser storage
Real-time event tickets	Server-side	Authentication for real-time event streams	Short-lived (seconds)
Stripe fraud prevention	Strictly necessary third-party cookies (Stripe)	Set only when you add a card or make a payment in the dashboard; Stripe uses them to detect fraudulent payments	1 year and 30 minutes
Cloudflare Turnstile	Strictly necessary third-party bot check (Cloudflare) on the dashboard's sign-up, sign-in and verification screens	Telling people from automated programs so that fraud and abuse stay out (Section 3.6)	Runs only on those screens
PostHog product analytics (dashboard)	Page memory only	Product analytics and session replay in the dashboard (Section 14.2). Nothing is stored on your device: no cookie and no browser storage.	Until you close or reload the page
Sign-in in the Talkif apps	Keychain on the Mac; on the iPhone, the Keychain (access token) and the app's cookie storage (sign-in cookie)	Keeps you signed in to the app	Until you sign out
Widget data (iPhone app)	App storage shared with the widgets on the iPhone (and a paired Apple Watch that runs the Talkif app)	Shows your agents, today's calls and your balance in widgets	Until you sign out
PostHog product analytics (Mac app)	App memory only	Product analytics in the Mac app (Section 14.2); no session recording	Until you quit the app
PostHog analytics cookie (talkif.ai)	First-party cookie on our public website	Counting visits to talkif.ai, only with "Analytics" consent	Up to 1 year
Cookie consent record	First-party cookie (CookieYes, talkif.ai only)	Remembers which cookie categories you allowed, so we only load what you agreed to	1 year
Campaign tag	Browser storage (talkif.ai)	Keeps the campaign (UTM) tag from the ad or link you arrived from, so a sign-up can be attributed to that campaign	Browser session
Google Analytics cookies (`_ga`, `_ga_*`)	Third-party analytics (talkif.ai only)	Website analytics, only with "Analytics" consent (Section 14.3)	Up to 2 years
Google Ads cookie (`_gcl_au`)	Third-party advertising (talkif.ai only)	Advertising measurement, only with "Advertisement" consent (Section 14.4)	90 days
OpenAI Ads pixel	Third-party advertising cookies and browser storage (talkif.ai and the Talkif dashboard)	Advertising measurement: on talkif.ai only with "Advertisement" consent; in the dashboard only while ad measurement is on (Section 14.4)	As set by OpenAI
Advertising event log	Browser storage (Talkif dashboard)	Remembers which actions were already reported, so none is counted twice. Exists only once ad measurement has been on.	Until you clear your browser storage

14.2 PostHog Product Analytics

We use PostHog (PostHog, Inc.) for product analytics and session replay. PostHog is hosted in the EU (Frankfurt) and processes data under a GDPR-compliant DPA.

What PostHog collects:

Data Element	Description
Page views and navigation	URLs visited, page load times, navigation flow
Click interactions	Autocaptured click events on UI elements
Session recordings	Page interactions, mouse movement, and scrolling behavior. All text inputs are masked. Password fields, phone numbers, and payment details are never captured.
User identity	User ID, email address, and full name (set upon authentication)
Device metadata	User agent, browser type and version, screen resolution, operating system
Approximate geolocation	Country and city-level location derived from IP address at ingestion. Raw IP addresses are not stored.

Nothing on your device in the dashboard: PostHog keeps its state in page memory only. It sets no cookie and writes nothing to browser storage. Your visits are linked by your Talkif user ID after you sign in, not by a device identifier.

What PostHog does NOT collect:

Raw IP addresses (discarded after geolocation derivation)
Password values or keystrokes in sensitive fields
Phone numbers or payment details (masked in session recordings)

Legal basis: Legitimate interest (GDPR Art. 6(1)(f)) for authenticated users of a B2B SaaS platform. We have conducted a balancing test confirming that product analytics and UX debugging for our authenticated business users does not override their rights and freedoms, given the limited data collected, EU-only hosting, and input masking in recordings.

Your rights: You may request access to, deletion of, or export of your PostHog analytics data by contacting privacy@talkif.ai.

On our public website (talkif.ai): PostHog runs only after you allow the "Analytics" category in Cookie settings. Visitors who do not allow it are not counted.

In the Talkif apps: the Mac app sends product analytics events to the same EU-hosted PostHog project, under the same legitimate interest, with all text from the screen masked and no session recording. It keeps nothing for analytics on your Mac, and each event carries the platform and the app version. The iPhone app sends no analytics.

14.3 Website Analytics (Google Analytics)

We use Google Analytics 4 on talkif.ai, our public website, to count visits and see which pages and campaigns bring visitors. It does not run in the Talkif dashboard.

When it runs: only after you allow the "Analytics" category in Cookie settings.
What it collects: pages visited, how you arrived (referrer and campaign tags), device and browser data, and approximate location. Google Analytics 4 does not log or store IP addresses.
What we do not do: we do not send names, email addresses, phone numbers or account data to Google Analytics. Google Signals is off, and Google Analytics is not linked to any advertising account.
Recipient: Google processes this data for us as our processor: Google Ireland Limited for visitors in the EEA, UK and Switzerland, Google LLC elsewhere.
Legal basis: consent (GDPR Art. 6(1)(a)).

14.4 Advertising Measurement

We advertise Talkif on platforms such as Google and ChatGPT. To learn which ads lead to real use of Talkif, we report certain actions back to the platform that showed the ad. When this happens depends on where you use Talkif:

On talkif.ai, only after you allow the "Advertisement" category in Cookie settings, wherever you are.
In the Talkif dashboard, in the EU/EEA, the UK, Switzerland and Turkey, only after you allow it: a separate, unticked checkbox when you sign up, or the "Ad measurement" setting in Settings → Preferences.
In the Talkif dashboard, everywhere else, from November 15, 2026 it is on by default for registered users; until then it is off until you allow it, as above. You can switch "Ad measurement" off in Settings → Preferences at any time.

The on-by-default rule for the dashboard outside the EU/EEA, the UK, Switzerland and Turkey was announced on 2026-10-16 and takes effect on 2026-11-15. It never applies to a choice you have already made.

We work out your region from the IP address of each request; if we cannot tell, we treat you as being in a region where you must allow it first. Once you make a choice in the dashboard, it is stored with your account and applies wherever you are. A Global Privacy Control (GPC) signal from your browser always turns ad measurement off. Accepting our Terms or this Policy is never a choice to allow it. While it is off, no advertising tag or pixel loads and nothing is reported.

Where	Platform	What is reported
talkif.ai (public website)	Google Ads	That a visit from a Google ad led to a sign-up click or a contact request
talkif.ai (public website)	OpenAI Ads	Page views, starting the website demo call, and submitting the contact form
Talkif dashboard (app.talkif.ai)	OpenAI Ads	Completing registration, your first connected browser call, adding a phone number, starting a checkout, and a successful payment (with its amount and currency)

Hashed email: for actions in the Talkif dashboard, we also send a SHA-256 hash of your email address so the platform can match the action to an ad you saw while signed in to it. The hash is computed in your browser; your email address itself is not sent.
What the platform also receives: like any web request, the tag or pixel gives the platform your IP address, browser data and the page it runs on, and it may set its own cookies.
What we never send: names, phone numbers, call content, transcripts, recordings, contact lists or payment card data. We do not upload customer lists and do not build custom or lookalike audiences.
Recipients: Google (Google Ireland Limited for the EEA, UK and Switzerland, Google LLC elsewhere) and OpenAI. Each uses this data under its own advertising terms and privacy policy, including to measure and improve its ads. See Google's privacy policy and OpenAI's privacy policy.
Legal basis: consent (GDPR Art. 6(1)(a)) on talkif.ai, and in the dashboard in the EU/EEA, the UK, Switzerland and Turkey; for Turkish residents, explicit consent under KVKK Articles 5 and 9. Elsewhere in the dashboard, from November 15, 2026 (consent until then), our legitimate interest in measuring our ads, which you can object to at any time by switching "Ad measurement" off in Settings.
Turning it off: turn the "Advertisement" category off in Cookie settings on talkif.ai, or turn "Ad measurement" off in Settings → Preferences in the dashboard, at any time. Reporting stops from that moment; actions reported before you turned it off are not recalled.

14.5 Managing Your Choices

Cookie settings are available on talkif.ai, where only strictly necessary cookies run until you choose. The Talkif dashboard shows no cookie banner: it sets no optional cookies of its own, and its one optional processing, ad measurement, is a setting on your account (Section 14.4). You can change or withdraw your choice at any time, and doing so is as easy as giving it. A Global Privacy Control (GPC) signal from your browser is treated as a refusal of advertising cookies on talkif.ai and of ad measurement in the dashboard, whatever the account setting says.

14.6 Tracking Technologies We Do NOT Use

We do not use:

The Meta Pixel or any other Meta advertising tag
Advertising tags or pixels on talkif.ai before you have allowed advertising cookies, or in the dashboard while ad measurement is off (Section 14.4)
Customer list uploads, custom audiences or lookalike audiences
Fingerprinting techniques beyond standard browser metadata

15. Children's Privacy

The Talkif Service is not directed to, and is not intended for use by, individuals under the age of:

16 years in the European Economic Area (or the age specified by the applicable EU member state, which may be as low as 13)
13 years in the United States (in compliance with the Children's Online Privacy Protection Act, "COPPA")
18 years in Turkey (or the age specified by applicable KVKK guidance)

We do not knowingly collect personal data from children below these age thresholds. If we become aware that we have inadvertently collected personal data from a child, we will take prompt steps to delete such data.

If you are a parent or guardian and believe your child has provided personal data to Talkif, please contact us at privacy@talkif.ai.

16. Data Processing Agreement (B2B Customers)

When Talkif processes personal data on behalf of a business customer (User) -- for example, when a User uploads a contact list and initiates calls to those contacts -- Talkif acts as a data processor under GDPR (or equivalent role under other laws), and the User acts as the data controller.

In such cases:

Talkif processes Call Recipient data solely on the User's instructions and for the purposes of providing the Service.
Users must have a lawful basis for processing Call Recipient data and must have obtained any required consents.
A Data Processing Agreement ("DPA") governs Talkif's processing of personal data on behalf of the User, in accordance with GDPR Article 28.

Our Data Processing Agreement is available at /dpa.

17. Links to Third-Party Services

The Service may contain links to or integrations with third-party websites and services (e.g., Stripe payment portal, Google OAuth consent screen). We are not responsible for the privacy practices of these third parties. Privacy policies for our sub-processors are available on their respective websites. See our Sub-processor List (Section 6.1) for the current list of third-party service providers. Apps and AI agents you connect to your account (Section 3.7) are third-party services too; their developers' privacy policies apply.

18. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes:

We will update the "Last Updated" date at the top of this Policy.
We will notify Users via email and/or a prominent notice within the Service at least 30 days before the changes take effect.
Where required by law, we will obtain your consent to material changes.

Your continued use of the Service after the effective date of a revised Policy constitutes acceptance of the changes. If you do not agree with the revised Policy, you must stop using the Service and may request account deletion.

19. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, you may contact us at:


General Privacy Inquiries	privacy@talkif.ai
Legal Department	legal@talkif.ai
Mailing Address	Talkif, Inc., 1111B S Governors Ave STE 23788, Dover, DE 19904 US

20. Jurisdiction-Specific Provisions

20.1 European Economic Area, United Kingdom, and Switzerland

Legal basis: We process personal data under the legal bases described in Sections 3 and 4 of this Policy.
Data transfers: See Section 7.
Supervisory authority: See Section 10.
Retention: See Section 8.

20.2 California, United States

CCPA/CPRA rights: See Section 11.
We do not sell personal information. Advertising measurement may count as "sharing" under the CCPA/CPRA. Section 6.4 explains when it runs; you can opt out at any time, and a Global Privacy Control (GPC) signal counts as an opt-out (Section 11.3).

20.3 Turkey

KVKK rights: See Section 12.

Processing Activity	Legal Basis	GDPR Article
Account creation and management	Contract performance	Art. 6(1)(b)
Authentication and security	Contract performance; Legitimate interest	Art. 6(1)(b); Art. 6(1)(f)
Voice call processing	Contract performance	Art. 6(1)(b)
Connectors (experimental)	Contract performance; User's instructions as controller	Art. 6(1)(b)
Billing and financial records	Contract performance; Legal obligation	Art. 6(1)(b); Art. 6(1)(c)
AI call analysis	Consent	Art. 6(1)(a)
Call recording	Consent (via User configuration)	Art. 6(1)(a)
Fraud prevention and security monitoring	Legitimate interest	Art. 6(1)(f)
Apps and AI agents you connect	Contract performance; User's instructions as controller	Art. 6(1)(b)
Talkif assistant	Contract performance; User's instructions as controller	Art. 6(1)(b)
Transactional email	Contract performance	Art. 6(1)(b)
Error monitoring and diagnostics	Legitimate interest	Art. 6(1)(f)
Product analytics and session replay	Legitimate interest	Art. 6(1)(f)
Website analytics (Google Analytics, talkif.ai)	Consent	Art. 6(1)(a)
Advertising measurement (Google Ads, OpenAI Ads)	Consent; from November 15, 2026, in the dashboard outside the EU/EEA, the UK, Switzerland and Turkey, legitimate interest (you can switch it off)	Art. 6(1)(a); Art. 6(1)(f)
Legal compliance (tax, regulatory)	Legal obligation	Art. 6(1)(c)
Service improvement (aggregate analytics)	Legitimate interest	Art. 6(1)(f)

Legitimate Interest Assessment: Where we rely on legitimate interest as a legal basis, we have conducted a balancing test to ensure our interests do not override the fundamental rights and freedoms of data subjects. Records of these assessments are available upon request.

Appendix B: Glossary

Term	Definition
Call Recipient	An individual who receives a voice call initiated through the Talkif platform. Also referred to as a "Data Subject" in certain contexts.
Data Controller	The entity that determines the purposes and means of processing personal data. For User account data, Talkif is the controller. For Call Recipient data uploaded by Users, the User is the controller.
Data Processor	The entity that processes personal data on behalf of a controller. Talkif acts as a processor when handling Call Recipient data on behalf of Users.
Data Subject	An identified or identifiable natural person whose personal data is processed.
DPA	Data Processing Agreement -- a contract between a data controller and data processor as required by GDPR Article 28.
DPO	Data Protection Officer -- an individual responsible for overseeing data protection compliance within an organization.
EEA	European Economic Area -- the EU member states plus Iceland, Liechtenstein, and Norway.
GDPR	General Data Protection Regulation (Regulation (EU) 2016/679).
CCPA	California Consumer Privacy Act of 2018 (Cal. Civ. Code Section 1798.100 et seq.).
CPRA	California Privacy Rights Act of 2020, amending and expanding the CCPA.
KVKK	Kisisel Verilerin Korunmasi Kanunu -- Turkey's Law No. 6698 on the Protection of Personal Data.
TCPA	Telephone Consumer Protection Act (47 U.S.C. Section 227).
LLM	Large Language Model -- an AI system that processes and generates natural language text.
STT	Speech-to-Text -- technology that converts spoken audio into written text.
TTS	Text-to-Speech -- technology that converts written text into synthesized speech audio.
SCCs	Standard Contractual Clauses -- EU-approved contractual mechanisms for international data transfers.

Questions about this document? Write to legal@talkif.ai.