Privacy Policy

Sections 1–13 apply to all products. Annexes A, B and C are product-specific and apply only to the product named. Where a product-specific annex conflicts with the common sections, the annex governs.

Part 1 — Common terms

1. Our role, and the organisation's role

Every VoxDonna product is deployed by an organisation — our client — to communicate with its own customers or to equip its own staff.

That organisation determines why and how personal data is processed. It is the Data Fiduciary under India's Digital Personal Data Protection Act, 2023, and the data controller under the EU/UK GDPR where applicable. VoxDonna acts as a Data Processor, handling data only on that organisation's documented instructions and under a written Data Processing Agreement.

Practically, this means:

• If you are a customer of one of our clients — you called their support line, messaged their WhatsApp number, or attended a meeting with their sales representative — your relationship is with that organisation. They decide what data is collected and for how long. We process it for them.
• If you are an employee of a client using our software, your employer is the controller of your account and usage data.

We will always help route your request to the right party. See Section 8.

2. What we never do with your data

These commitments apply across every product, without exception:

• We do not sell personal data, and never have.
• We do not share personal data with data brokers, ad networks, or advertising platforms.
• We do not use client data, conversations, recordings or transcripts to train or improve any AI model — ours or a third party's. Our AI sub-processors are contractually prohibited from doing so.
• We do not use one client's data to serve another client. Data is isolated per organisation at the database level.
• We do not use personal data for our own marketing or to build profiles of individuals for any purpose other than delivering the service to the client who owns the data.
• We do not combine data across products or clients to create enriched profiles.

3. You are talking to an AI

Where a VoxDonna Voice Agent or WhatsApp Agent handles a conversation, you are interacting with an automated system, not a human. Our agents identify themselves as automated at the start of an interaction, and clients are contractually required to keep that disclosure in place. You may ask at any point to be transferred to a human, and clients configure an escalation path for this.

This reflects our obligations and our clients' obligations under transparency rules for AI systems, including Article 50 of the EU AI Act where the interaction reaches a person in the European Union.

4. Automated decisions

Our outbound agents may score or categorise a conversation — for example, marking a lead as qualified or unqualified, or routing a complaint by urgency. These outputs are recommendations passed to the client organisation; they are not final decisions and do not by themselves produce legal or similarly significant effects. Any decision about you — whether to offer a product, extend credit, or act on a complaint — is made by the client organisation under its own policies. Where the GDPR applies, you may ask that organisation for human review of any decision.

5. AI accuracy

Transcripts, summaries, translations, classifications and agent responses are produced by automated systems and may contain errors, omissions or misattributions — particularly with accented speech, crosstalk, background noise, poor call quality, or multilingual conversation. They are an operational aid, not a verbatim or legal record, and should not be relied on as evidence of what any person said or agreed. Client organisations are responsible for verifying anything material before acting on it.

6. Security

We protect personal data with:

• encryption in transit (TLS) and at rest;
• per-organisation and per-role data isolation at the database level;
• role-based access controls, with internal access limited to personnel who need it to operate or support the service;
• short-lived signed links for all audio and media access;
• on-device AES-256 encryption where the product stores data on a device.

No system is perfectly secure, but we apply measures appropriate to the sensitivity of the data.

In the event of a personal data breach, we will notify the affected organisation without undue delay, and will notify the Data Protection Board of India and affected individuals as required by the Digital Personal Data Protection Act, 2023 and its rules. Where the GDPR applies, we will support the client organisation in meeting its 72-hour notification obligation.

7. Retention and deletion

Retention is set by each client organisation. Where an organisation has not specified a period, our defaults are:

On request: where a client organisation or an authorised individual requests deletion and we are permitted to act on it, we delete the data from active systems within 30 days. Residual copies in encrypted backups are overwritten on our standard backup cycle within a further 35 days, during which they remain encrypted and inaccessible for ordinary use.

On termination: when a client's contract ends, we return or delete its data at its election within 60 days, subject to any retention we are legally required to observe.

8. Your rights

Subject to applicable law, and to the client organisation's role as Data Fiduciary / controller, you may:

• access the personal data we hold about you and a summary of how it is processed;
• correct data that is inaccurate, and complete data that is incomplete;
• request erasure of your personal data;
• withdraw consent you previously gave, where processing relies on consent;
• nominate another individual to exercise these rights on your behalf in the event of your death or incapacity (Digital Personal Data Protection Act, 2023);
• raise a grievance with us and receive a response — see Section 10;
• complain to the Data Protection Board of India or, where the GDPR applies, to your local supervisory authority.

Where the GDPR applies, you additionally have rights to restriction of processing, to object to processing, and to data portability. These are ordinarily exercised through the client organisation as controller.

How to exercise them. If you know which organisation you dealt with, contact them first — they hold the decision. You may also write to admin@voxdonna.com and, acting as that organisation's processor, we will route your request to them and support them in responding. We respond within 30 days. We may need to verify your identity, and where you are not the client organisation, we may need its authorisation before acting.

9. Legal disclosures

We may disclose personal data where required by law, by a binding order of a court or authority of competent jurisdiction, or to establish or defend legal claims. Where we are permitted to do so, we will notify the client organisation first.

10. Grievance Officer

In accordance with the Digital Personal Data Protection Act, 2023:

We acknowledge grievances within 7 days and aim to resolve them within 30 days.

11. Children

VoxDonna products are business tools, intended for use by organisations and their staff and for communication with adult customers. They are not directed to children, and we do not knowingly collect personal data from children. If we learn that we have done so, we will delete it.

12. Changes to this policy

We may update this policy from time to time. Material changes will be reflected by updating the "Last updated" date above and, where the change materially affects how data is handled, by advance notice to client organisations.

13. Governing law

This policy is governed by the laws of India. The courts at New Delhi have exclusive jurisdiction, without prejudice to any mandatory rights you have under the law of your country of residence.

Part 2 — Product annexes

Annex A — VoxDonna Voice Agents

Applies where an AI voice agent handles inbound customer calls or places outbound calls on behalf of a client organisation.

A1. What we process

• Call audio — the recording of the conversation between you and the agent.
• Transcripts and derived content — text of the conversation, summaries, categorisation, sentiment and outcome tags.
• Your phone number, and the date, time and duration of the call.
• Information you provide during the call — your name, account or policy number, order details, the nature of your complaint or enquiry, and anything else you choose to say.
• Data the client organisation already holds about you, supplied to the agent so it can serve you — for example your customer record, order status, or the fact that you requested a callback.

A2. Recording and consent

Calls are recorded. The client organisation is responsible for announcing this and for obtaining any consent required by the law of the place where the call takes place, and for honouring your objection. Our agents deliver a recording disclosure at the start of the call as configured by that organisation. If you do not wish to be recorded, tell the agent or ask to be transferred.

A3. Outbound calls

Where an agent calls you, your number and the reason for the call are supplied by the client organisation, which is responsible for having a lawful basis to contact you and for complying with applicable telemarketing rules — including, in India, TRAI's Telecom Commercial Communications Customer Preference Regulations and Do Not Disturb registry obligations, and in other jurisdictions the equivalent consent and calling-hours rules. We do not source, buy, or supply calling lists.

To stop receiving calls, tell the agent during the call — it will record your request and pass it to the client organisation — or contact that organisation directly.

A4. Where this data is processed

Voice agent processing location depends on the client's deployment. For Indian deployments, speech recognition, language processing and storage are performed within India. Telephony connectivity is provided by our client's or our telecommunications provider, and speech synthesis by our speech technology provider, which may process audio outside India. Client organisations are told the exact processing locations and named providers for their deployment in their Data Processing Agreement.

A5. Integration with client systems

Where a client connects VoxDonna to its own systems — such as Salesforce, SAP, or a helpdesk — call outcomes, summaries and the details you provide are written into those systems. Once written, that data is held by the client organisation under its own privacy policy and retention rules, and requests about it should be directed to them.

Annex B — VoxDonna WhatsApp Agents

Applies where an AI agent responds to customer messages on a client organisation's own WhatsApp Business account.

B1. Our relationship with Meta

VoxDonna is a technology provider to businesses that use the WhatsApp Business Platform. Our clients own their WhatsApp Business accounts. We connect to those accounts with the client's authorisation to send and receive messages on their behalf.

B2. Platform Data we receive from Meta

To operate the service we receive from Meta:

• the client's WhatsApp Business Account and registered phone number details;
• messages sent by you to the client's WhatsApp number — text, images, documents, and voice notes;
• your WhatsApp phone number and WhatsApp profile name, as provided by WhatsApp when you message the business;
• message delivery and read statuses for messages the business sends you;
• message template approval statuses for the templates the client has registered.

B3. How we use Platform Data

Solely to deliver the messaging service to the client who owns the account: routing your message to that client's configured AI agent, generating a reply, sending it back in the same conversation, and showing the client its own conversation and delivery history in the VoxDonna dashboard.

We use Platform Data only on behalf of, and at the direction of, the client whose account it belongs to. In addition to the commitments in Section 2, and consistent with Meta's Platform Terms and the WhatsApp Business Messaging Policy:

• we do not sell or license Platform Data;
• we do not transfer Platform Data to data brokers, ad networks, or monetisation platforms;
• we do not use Platform Data to build advertising profiles, or for any purpose unrelated to the service the client has engaged us to provide;
• we do not use Platform Data to train AI models;
• we delete Platform Data on the client's instruction, and on termination of the client's use of the service, in accordance with Section 7 and Meta's requirements.

B4. Message content and encryption

WhatsApp messages between you and a business using the WhatsApp Business Platform are not end-to-end encrypted in the same way as personal WhatsApp chats. Businesses that use the platform — and technology providers acting for them, including us — can read the messages you send them, which is what allows a business to answer you. Meta explains this at the start of a business conversation.

Messages transit Meta's WhatsApp Business Platform infrastructure, which Meta operates and which may be located outside India, before reaching us. We hold the resulting conversation history in our own environment in India (Amazon Web Services, ap-south-1).

B5. Opting out

To stop receiving messages from a business, reply to that conversation asking to opt out, use any opt-out option offered in the message, or block the business in WhatsApp. Opt-out requests are recorded and passed to the client organisation, which is responsible for honouring them. You may also report a business to WhatsApp directly.

Annex C — FieldVoice

Applies to the FieldVoice mobile app and web dashboard, used by a client organisation's own field teams to record and summarise customer meetings. FieldVoice may be listed on the App Store under an organisation-specific name.

C1. What we process

• Account and identity — your name and work email, obtained when you sign in with your organisation's Microsoft (Entra ID) account. FieldVoice does not create, see, or store your password.
• Meeting recordings — audio recorded during customer meetings, captured only after an explicit on-screen consent step at the start of each recording.
• Derived content — transcripts, AI-generated summaries and action items.
• Meeting details — the customer, date and time, and participants you associate with a meeting.
• Crash diagnostics — see C5.

C2. People recorded who are not FieldVoice users

When a FieldVoice user records a meeting, other participants — typically the client organisation's customers or their staff — are also recorded. Their voices, and any personal information they mention, form part of the recording, transcript and summary.

Responsibility for informing those participants, and for obtaining any consent required by the law of the place where the meeting occurs, rests with the organisation deploying FieldVoice. Recording laws differ by jurisdiction: some require only that one participant consents, while others — including France and most of the European Economic Area — require that all participants are informed, and in some cases that they affirmatively agree.

FieldVoice displays an on-screen notice at the start of every recording and will not begin recording until it is acknowledged.

If you were recorded in a FieldVoice meeting and wish to access, correct or delete that recording, contact the organisation that arranged the meeting, or write to us at admin@voxdonna.com and we will route your request to them.

C3. AI processing

Transcription is performed using the Sarvam, Bhashini and Amazon Transcribe APIs operating within India. Summaries and action items are generated using Amazon Bedrock in the AWS ap-south-1 (Mumbai) region. Amazon Bedrock does not use inputs or outputs submitted to it to train any foundation model, and does not share them with model providers.

Speaker separation is not biometric identification. FieldVoice distinguishes between speakers within a single recording so that transcripts are readable. We do not create, store or match voiceprints, and we do not use audio to identify a person across recordings.

C4. Data residency

All meeting data — recordings, transcripts, summaries and meeting details — is processed and stored exclusively in India, on Amazon Web Services in the ap-south-1 (Mumbai) region.

• Audio stored on your device is encrypted with AES-256. Once it uploads successfully, the local copy is deleted.
• Audio in the cloud is private and accessible only through short-lived, signed links.

Two categories of data are handled outside this arrangement, and neither contains meeting content: sign-in, which runs through your organisation's own Microsoft Entra ID tenant under that organisation's configuration; and crash diagnostics, described below.

C5. Crash reporting

FieldVoice uses Google Firebase Crashlytics to detect and diagnose app crashes. When a crash occurs, Crashlytics receives the technical stack trace, your device model, operating system version and app version, the state of the app at the moment of failure, and a randomly generated installation identifier.

Crashlytics does not receive your recordings, transcripts, summaries, meeting details, name or email address. We do not attach custom identifiers and do not use Crashlytics to identify individual users. This data may be processed on Google infrastructure outside India, including in the United States.

C6. Deleting your account

You can request deletion of your FieldVoice account and associated data by writing to admin@voxdonna.com or contacting your organisation's administrator. Because your organisation is the Data Fiduciary, we will confirm the request with it before acting, and will tell you the outcome.

Part 3 — Sub-processors and transfers

Sub-processors

Each sub-processor acts on our instructions under written terms prohibiting use of the data for their own purposes, including model training. We maintain this list and will notify client organisations before adding or replacing a sub-processor that handles customer content.

International transfers

Organisations established in the EEA or UK. India has not received an adequacy decision from the European Commission. Where a VoxDonna product is deployed by an organisation subject to the GDPR, transfers of personal data to VoxDonna in India are made under the European Commission's Standard Contractual Clauses, and the UK International Data Transfer Addendum where applicable, incorporated into our Data Processing Agreement with that organisation. Transfers to Meta, Google and other sub-processors located outside India or the EEA are made under those providers' own data processing terms and Standard Contractual Clauses. Copies are available on request.

Cookies

The VoxDonna web dashboard uses strictly necessary cookies to keep you signed in and to maintain session security. We do not use advertising, tracking, or third-party analytics cookies on the dashboard. Because these cookies are essential, they cannot be disabled without preventing sign-in.