Privacy Policy - Voxcee

PRIVACY POLICY

“Voxcee (“Voxcee”, “we”, “us”, or “our”) respects your privacy and is committed to protecting personal data processed through our website, products, services, applications, AI voice agents, communication platforms and related services.

This Privacy Policy explains how we collect, use, process, store, disclose and protect personal data when you:

visit www.voxcee.com or other websites operated by us;

contact us or submit an enquiry;

request or participate in a demonstration;

create or use a Voxcee account;

use Voxcee's AI voice-agent and communication services;

interact with an AI voice agent operated using the Voxcee platform;

receive or make calls through services powered by Voxcee;

communicate with our sales, support or customer-success teams; or

otherwise interact with Voxcee.

This Privacy Policy should be read together with any applicable Terms of Service, Data Processing Agreement (“DPA”), customer agreement, cookie notice or other privacy notice provided in connection with a particular Voxcee service.

1. About Voxcee

Voxcee provides AI-powered voice-agent and business communication technology that enables organisations to automate and manage telephone conversations and related workflows.

Depending on the customer’s configuration, Voxcee services may be used for purposes including:

customer service;

inbound call handling;

outbound customer communication;

lead qualification;

appointment booking;

reminders and notifications;

customer surveys;

collections and payment reminders;

customer verification;

sales enquiries;

customer-support automation;

call routing and transfers;

conversational analytics; and

integration with CRM, contact-centre and other business systems.

Voxcee may operate as a data controller/data fiduciary for certain personal data that we collect for our own purposes, and as a data processor/service provider when processing personal data on behalf of our business customers.

2. Who Is Responsible for Your Personal Data?

The organisation responsible for your personal data depends on how you interact with Voxcee.

2.1 Website Visitors, Prospects and Voxcee Customers

Where you visit our website, contact us, request a demonstration, subscribe to communications or enter into a direct commercial relationship with Voxcee, the relevant Voxcee legal entity generally determines how and why your personal data is processed.

In these circumstances, Voxcee may act as a data controller or data fiduciary.

2.2 Individuals Interacting with a Customer's AI Voice Agent

If you receive a call from, or make a call to, an organisation using Voxcee, that organisation will generally determine

why the call takes place;

whose telephone numbers are contacted;

what information is collected;

the purpose of the conversation;

what actions the AI voice agent is permitted to perform; and

how long the relevant customer wishes to retain the information.

In these circumstances, the Voxcee customer will generally be the controller/data fiduciary and Voxcee will generally process the information on that customer’s behalf as its processor/service provider.

If you wish to exercise privacy rights relating to such a call, you should normally contact the organisation on whose behalf the call was made.

Voxcee will assist its customers in responding to valid data-protection requests where required by applicable law and our contractual obligations.

3. Personal Data We May Collect

The personal data we process depends on how you interact with Voxcee and how a customer configures the Voxcee platform.

3.1 Contact and Identity Information

We may collect

name;

business email address;

telephone or mobile number;

job title;

employer or organisation;

country or region;

business address; and

other information you voluntarily provide.

3.2 Account Information

Where an account is created, we may process

username;

account identifiers;

authentication information;

organisation details;

user roles and permissions;

account settings; and

login and security records.

We do not intentionally store passwords in plain text.

3.3 Sales and Marketing Information

We may process information relating to

product enquiries;

demonstration requests;

sales conversations;

event participation;

marketing preferences;

communications with our sales team;

products or services in which you have expressed an interest; and

business relationship history.

3.4 Voice and Call Data

When Voxcee technology is used to facilitate a telephone conversation, we may process, depending on customer configuration

telephone numbers;

caller and recipient identifiers;

call date and time;

call duration;

call status;

call routing information;

audio recordings;

speech-to-text transcripts;

responses provided during conversations;

AI-generated responses;

call summaries;

conversation outcomes;

call disposition;

transfer information; and

technical information associated with the call.

Whether calls are recorded may depend on the customer’s configuration and applicable legal requirements.

Customers using Voxcee are responsible for ensuring that appropriate notices, permissions or consents are provided where required by applicable law.

3.5 Conversation Content

Information provided during a conversation with a Voxcee-powered AI voice agent may be processed to:

understand the caller's request;

generate an appropriate response;

execute authorised workflows;

transfer calls;

update customer systems;

produce transcripts or summaries;

classify call outcomes; and

provide reporting and analytics.

The information contained in a conversation depends on what the caller provides and how the customer has configured the service.

3.6 Customer-Provided Data

Our business customers may provide personal data to Voxcee for processing through the platform. This may include

names;

telephone numbers;

customer IDs;

lead information;

appointment information;

account information;

CRM records;

campaign information; and

other information required to perform the customer's requested workflow.

Voxcee processes such information in accordance with the customer’s instructions, applicable agreements and applicable law.

3.7 Technical and Device Information

When you access our website or platform, we may automatically collect information such as

IP address;

browser type;

operating system;

device type;

approximate geographic region derived from IP address;

pages visited;

referring pages;

timestamps;

session information;

diagnostic information;

application logs; and

security events.

3.8 Integration Data

Customers may connect Voxcee with third-party applications such as CRM, helpdesk, scheduling, communication, telephony or business systems. When integrations are enabled, we may process information exchanged between Voxcee and those systems as necessary to provide the requested integration.

4. Special or Sensitive Personal Data

Voxcee is not designed to require individuals to provide sensitive personal data unless such processing is specifically required for a customer’s authorised use case and permitted under applicable law.

Depending on the customer’s industry and the nature of a conversation, however, individuals may voluntarily disclose information that could be considered sensitive or special-category data.

Customers are responsible for ensuring that their use of Voxcee to process sensitive information is lawful and appropriately configured.

Where Voxcee processes such information on behalf of a customer, we process it in accordance with the customer’s documented instructions and applicable contractual and legal requirements.

5. How We Collect Personal Data

We may collect personal data

Directly from You

For example, when you

submit a website form;

request a demonstration;

contact our team;

create an account;

attend an event;

subscribe to marketing communications; or

interact with a Voxcee-powered voice agent.

From Our Customers

Business customers may provide data required to configure and operate their Voxcee services.

Through Integrations

Information may be received from CRM systems, contact-centre platforms, scheduling tools, telephony platforms or other services connected by our customers.

Automatically

Certain technical information may be collected through cookies, server logs, analytics technologies and similar mechanisms.

From Legitimate Business Sources

Where permitted by law, we may receive professional or business contact information from

publicly available sources;

business directories;

event organisers;

marketing partners;

professional networks; and

business-data providers.

6. How We Use Personal Data

We may process personal data for the following purposes.

Providing the Voxcee Service

To

operate AI voice agents;

process inbound and outbound calls;

convert speech to text;

generate voice responses;

route and transfer calls;

execute customer-defined workflows;

integrate with third-party systems;

create transcripts and summaries;

provide reporting and analytics; and

maintain customer accounts.

Customer Support

To

respond to enquiries;

investigate technical problems;

provide implementation assistance;

manage customer relationships; and

provide technical and operational support.

Security and Fraud Prevention

To

authenticate users;

prevent unauthorised access;

detect suspicious activity;

investigate security incidents;

protect our systems and customers; and

maintain service integrity.

Service Administration

To

administer accounts;

monitor service performance;

manage billing;

maintain records;

communicate service updates; and

enforce contractual terms.

Improving Our Services

We may analyse appropriately authorised and, where practical, aggregated or de-identified information to understand service performance, improve reliability, enhance product functionality and develop new capabilities.

Where customer content is proposed to be used for AI model training or another materially different purpose, such processing will be governed by the applicable customer agreement, product configuration and applicable law.

Sales and Marketing

Where permitted by applicable law, we may use business contact information to

respond to enquiries;

provide requested information;

communicate about relevant Voxcee services;

invite individuals to events or demonstrations;

provide product updates; and

conduct B2B marketing.

Individuals may opt out of marketing communications at any time.

Legal and Compliance Purposes

We may process information where reasonably necessary to

comply with applicable law;

respond to lawful government or regulatory requests;

establish or defend legal claims;

enforce our agreements;

investigate suspected misuse; and

comply with legal, tax, accounting or regulatory requirements.

7. Legal Bases for Processing

Where applicable data-protection law requires a legal basis, we may rely on one or more of the following

Contract

Processing may be necessary to provide services requested by you or perform our contractual obligations.

Legitimate Interests

We may process personal data where necessary for legitimate business interests, provided those interests are not overridden by applicable privacy rights. These interests may include

operating and improving our services;

protecting our systems;

preventing fraud;

providing customer support;

managing business relationships; and

conducting appropriate B2B marketing.

Consent

Where required, we may rely on consent for particular processing activities. Where processing is based on consent, consent may generally be withdrawn at any time, subject to applicable law.

Legal Obligation

We may process information where required to comply with applicable legal or regulatory obligations.

Other Lawful Grounds

Where other lawful grounds are recognised under applicable data-protection legislation, we may rely upon those grounds where appropriate.

8. AI and Automated Processing

Voxcee provides artificial-intelligence technology capable of understanding speech, generating responses and performing customer-configured actions.

When you interact with a Voxcee-powered AI voice agent, automated systems may

convert your speech into text;

analyse the meaning of your request;

identify relevant information;

generate an appropriate response;

convert generated text into speech;

classify the conversation;

summarise the call;

trigger authorised workflows; or

determine whether a call should be transferred to a human agent.

The specific functions performed depend on how the Voxcee customer has configured its AI voice agent.

Most interactions with a Voxcee voice agent involve routine, non-consequential actions, such as answering a query or booking an appointment. Where an interaction leads to a decision that produces a legal or similarly significant effect on an individual (for example, declining a service, an eligibility determination, or a financial or credit-related outcome), the customer’s configuration determines whether that decision is made automatically or escalated for human review. Where applicable law provides rights relating to decisions based solely on automated processing that produce legal or similarly significant effects, those rights will be respected.

Customers must not configure Voxcee to make legally prohibited automated decisions.

9. Call Recording and Transcription

Voxcee supports call recording and transcription capabilities. Whether a particular call is recorded or transcribed depends on

customer configuration;

the purpose of the service;

applicable laws;

customer instructions; and

technical requirements.

Customers are responsible for determining whether they are legally permitted to record or transcribe conversations and for providing appropriate notices or obtaining consent where required.

Where Voxcee processes recordings or transcripts solely on behalf of a customer, the customer determines the applicable purpose and retention requirements, subject to the customer agreement.

10. How We Share Personal Data

We do not disclose personal data indiscriminately. Personal data may be shared with the following categories of recipients where necessary.

Service Providers and Subprocessors

We may engage third parties that provide

cloud infrastructure;

data hosting;

telecommunications;

speech recognition;

text-to-speech technology;

artificial-intelligence infrastructure;

cybersecurity

analytics;

monitoring;

email;

CRM;

customer support;

payment processing; and

other technology necessary to operate Voxcee.

These providers are permitted to process personal data only as authorised under applicable agreements and law.

Telecommunications Providers

These providers are permitted to process personal data only as authorised under applicable agreements and law.

Customer-Selected Integrations

Where a customer connects Voxcee to another service, information may be transferred to that service according to the customer’s instructions.

Professional Advisers

Information may be disclosed where necessary to legal advisers, accountants, auditors, insurers or other professional advisers.

Government and Regulatory Authorities

We may disclose information where required by law, regulation, court order or other valid legal process.

Corporate Transactions

If Voxcee or the relevant business is involved in a merger, acquisition, restructuring, financing or sale of assets, information may be transferred as part of that transaction subject to appropriate safeguards.

11. Sale of Personal Data

Voxcee does not sell personal data in the conventional sense of selling databases of customer or caller information for monetary consideration.

Where applicable privacy legislation defines sale, sharing or similar concepts more broadly, we will comply with applicable disclosure and opt-out obligations.

12. International Data Transfers

Voxcee may operate across multiple jurisdictions, and our customers, infrastructure providers and technology partners may be located in different countries. As a result, personal data may be processed outside the country in which it was originally collected.

Where required by applicable law, Voxcee uses appropriate mechanisms and safeguards for international transfers of personal data. These may include

contractual data-protection clauses;

standard contractual clauses;

international data-transfer agreements;

recognised adequacy mechanisms; and

additional technical and organisational safeguards.

The precise transfer mechanism depends on the countries involved and applicable law.

13. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected or as required by applicable law. Retention periods vary depending on

the type of information;

the purpose of processing;

customer configuration;

contractual obligations;

legal requirements;

security requirements; and

dispute-resolution requirements.

Customer call recordings, transcripts and conversation data may be retained according to the customer’s selected configuration and contractual arrangements.

After the applicable retention period, information will be deleted, anonymised or otherwise handled in accordance with our data-retention procedures and applicable law.

Backup copies may remain for a limited period until overwritten or securely deleted through normal backup-management processes.

14. Data Security

Voxcee takes reasonable and appropriate technical and organisational measures designed to protect personal data against

unauthorised access;

accidental loss;

destruction;

alteration;

misuse;

unauthorised disclosure; and

unlawful processing.

Depending on the relevant system, safeguards may include

encryption in transit;

encryption at rest where appropriate;

access controls;

authentication;

role-based permissions;

logging and monitoring;

network security controls;

vulnerability management;

secure software-development practices;

backup procedures;

incident-response procedures; and

vendor security assessments.

No electronic system or internet transmission can be guaranteed to be completely secure. We therefore cannot guarantee absolute security of information.

15. Data Breaches

Voxcee maintains procedures for identifying, investigating and responding to suspected personal-data breaches.

Where a breach requires notification under applicable law, Voxcee will notify the relevant customers, regulators or affected individuals as required within the applicable statutory timeframes.

Where Voxcee acts as a processor, we will notify the relevant customer in accordance with applicable contractual and legal obligations.

16. Your Privacy Rights

Depending on where you live and the applicable law, you may have rights concerning your personal data. These may include the right to

obtain information about how your personal data is processed;

request access to your personal data;

request correction of inaccurate personal data;

request completion of incomplete information;

request deletion or erasure;

restrict certain processing;

object to certain processing;

withdraw consent;

request portability of your data;

object to direct marketing;

request information about automated decision-making;

lodge a complaint with an appropriate supervisory authority; and

exercise other rights provided by applicable law.

These rights are not absolute and may be subject to statutory exceptions. We may need to verify your identity before fulfilling certain requests.

17. India Privacy Rights

Where India’s Digital Personal Data Protection Act, 2023 and applicable rules apply, Voxcee will process digital personal data in accordance with applicable obligations under that framework.

Depending on the circumstances and applicable provisions, Data Principals may have rights including rights relating to

access to information about personal-data processing;

correction and updating of personal data;

erasure of personal data;

grievance redressal; and

nomination as provided by applicable law.

Grievances relating to Voxcee’s own processing of personal data may be raised with our Grievance Officer using the contact details in Section 30.

Where Voxcee acts as a Data Processor for a business customer, requests concerning customer-controlled information should generally be directed to the relevant customer.

18. United Kingdom and EEA Privacy Rights

Where the UK GDPR, EU GDPR or equivalent legislation applies, individuals may have rights including

right of access;

right to rectification;

right to erasure;

right to restriction of processing;

right to data portability;

right to object;

right to withdraw consent; and

rights relating to certain automated decision-making.

Individuals may also have the right to complain to the relevant data-protection supervisory authority. For individuals in the United Kingdom, this may include the Information Commissioner’s Office (“ICO”).

19. California Privacy Rights

If applicable California privacy legislation applies to Voxcee’s processing of your information, California residents may have rights including

the right to know what personal information is collected;

the right to know the purposes for which information is used;

the right to know categories of third parties to whom information is disclosed;

the right to request deletion, subject to exceptions;

the right to request correction;

the right to opt out of certain sales or sharing of personal information where applicable;

rights relating to certain sensitive personal information; and

the right not to receive discriminatory treatment for exercising applicable privacy rights.

Voxcee does not discriminate against individuals for exercising legally protected privacy rights.

20. Direct Marketing

Where permitted by law, Voxcee may send relevant business communications to customers, prospective customers and business contacts.

You can unsubscribe from marketing communications at any time by

using the unsubscribe mechanism included in an email; or

contacting us using the details provided in this Privacy Policy.

Opting out of marketing does not prevent us from sending essential service, security, transactional or account communications.

21. Cookies and Similar Technologies

Our website may use cookies and similar technologies to

operate essential website functionality;

maintain security;

remember preferences;

understand website usage;

measure performance; and

support marketing activities where permitted.

Cookies that are strictly necessary may be used without consent where permitted by law.

Where applicable law requires consent for analytics, advertising or other non-essential cookies, such technologies will be activated according to the choices provided through our cookie-management mechanism.

Users can also control cookies through their browser settings. Where Voxcee publishes a separate Cookie Policy, it will provide further detail on the specific cookies used and how to manage them.

22. Third-Party Links

Our website may contain links to websites, services or applications operated by third parties. Voxcee is not responsible for the privacy practices of independent third parties. We encourage users to review the privacy policies of third-party services before providing personal information.

23. Children's Privacy

Voxcee is a business technology platform and is not intended to be marketed directly to children.

We do not knowingly collect personal data directly from children through the Voxcee website for independent marketing purposes.

Customers are responsible for ensuring that any use of Voxcee involving minors complies with applicable laws, including requirements concerning parental or guardian consent where applicable.

If we become aware that personal data relating to a child has been processed unlawfully, we will take appropriate steps in accordance with applicable law.

24. Customer Responsibilities

Customers using Voxcee are responsible for ensuring that their use of the service complies with applicable privacy, telecommunications, marketing, recording and consumer-protection laws. Among other things, customers are responsible for

having a lawful basis for contacting individuals;

providing legally required privacy notices;

obtaining consent where required;

complying with telemarketing and do-not-call requirements;

configuring call recording appropriately;

providing lawful instructions to Voxcee;

ensuring uploaded contact data was obtained lawfully;

responding to individuals' privacy requests; and

avoiding prohibited or unlawful uses of the service.

Use of Voxcee does not itself make a customer’s calling campaign legally compliant.

25. Do-Not-Call and Communication Preferences

Recipients of communications made through Voxcee may have rights under applicable telecommunications and marketing laws.

Customers using Voxcee for outbound communication are responsible for respecting applicable

do-not-call registries;

suppression lists;

opt-out requests;

consent requirements; and

telemarketing restrictions.

Where Voxcee receives an opt-out request relating to a customer’s communication, we may communicate that request to the relevant customer or otherwise process it in accordance with applicable law and contractual obligations.

26. Data Processing on Behalf of Customers

Where Voxcee processes personal data on behalf of a customer, our processing is governed by the applicable customer agreement and, where required, a Data Processing Agreement. Such arrangements may address matters including

processing instructions;

confidentiality;

information security;

subprocessors;

international transfers;

assistance with data-subject requests;

security incidents;

deletion and return of information; and

audit and compliance obligations.

Business customers requiring a Data Processing Agreement should contact Voxcee.

27. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect

changes to our services;

changes to our technology;

changes to our data-processing activities;

changes in applicable law; or

changes to regulatory guidance.

When we make material changes, we will update the Last Updated date at the top of this Privacy Policy and, where appropriate or legally required, provide additional notice.

We encourage users to review this Privacy Policy periodically.

28. How to Exercise Your Privacy Rights

To exercise an applicable privacy right, you may contact Voxcee using the privacy contact information provided below. Please include sufficient information for us to

understand your request;

identify the relevant data;

determine whether Voxcee or a Voxcee customer controls that data; and

verify your identity where legally required.

If your request relates to an organisation that contacted you using Voxcee, we may direct you to that organisation or forward the request where appropriate.

We will respond within the period required by applicable law.

29. Grievances and Complaints

If you have concerns regarding how your personal data has been handled, please contact us first so that we can investigate the matter.

You may also have the right to lodge a complaint with the applicable data-protection authority or regulatory body in your jurisdiction.

Nothing in this Privacy Policy limits any statutory right to contact a regulator directly.

30. Contact Us

For questions about this Privacy Policy, our privacy practices or your personal data, please contact

Voxcee – Privacy Team
Grievance Officer / Data Protection Contact

Please direct grievances and data-protection queries to support@voxcee.com, marked for the attention of the Grievance Officer.

Registered Office

Vivacom Ltd

AMBA House, 15 College Road, Harrow, HA1 1BA, United Kingdom

For customer-specific calls or communications, you may also contact the organisation on whose behalf the Voxcee-powered communication was made.

31. Additional Customer Privacy Information

Individual Voxcee customers may have privacy policies containing additional information about how they use Voxcee and other technologies.

Where you interact with a Voxcee-powered AI agent on behalf of another organisation, you should review that organisation’s privacy policy in addition to this Privacy Policy.