This is a preliminary translation. The Portuguese version is authoritative. For questions, contact us at juridico@talkover.ai.

1. Introduction

Welcome to Talkover ("we", "us" or "our"). We provide artificial intelligence call solutions for businesses. This Privacy Policy explains how we collect, use, disclose and protect your personal information when you visit our website and interact with our services. By using our website or submitting your information through our forms, you agree to the practices described in this policy. Talkover values privacy and the protection of personal data, always aiming to provide the best service, product and/or experience for you, ensuring that your use complies strictly with the law and good information security practices.

To make this possible, we maintain a continuous and permanent privacy and data governance program, managed by a Privacy and Data Protection Committee and supported by the Data Protection Officer (DPO), who is the link between us, you and the relevant supervisory authority.

1.1 Definitions

To clarify the terms used in this policy, we present the following definitions:

Personal data: information relating to an identified or identifiable natural person
Sensitive personal data: personal data concerning racial or ethnic origin, religious belief, political opinion, trade union membership, religious, philosophical or political organization membership, health or sex life data, genetic or biometric data, when linked to a natural person
Anonymized data: data relating to a data subject that cannot be identified, considering the use of reasonable and available technical means at the time of processing
Database: structured set of personal data, established in one or more locations, in electronic or physical form
Data subject: the natural person to whom the personal data being processed refers
Controller: natural or legal person, under public or private law, responsible for decisions regarding the processing of personal data
Processor: natural or legal person, under public or private law, that processes personal data on behalf of the controller
DPO: person appointed by the controller and processor to act as a communication channel between the controller, data subjects and the supervisory authority
Processing: any operation performed with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction
Consent: a free, informed and unambiguous expression by which the data subject agrees to the processing of their personal data for a specific purpose

2. Roles and Responsibilities

Controller: Client (company using the AI agents), who decides what data to collect and how to use it. Legally responsible under LGPD, GDPR or CCPA. Must justify the legal basis, inform data subjects and ensure their rights.
Processor: Talkover, which only processes data on behalf of the client without determining purposes. Ensures traceability of data operations; maintains access and processing logs; provides channels to report security failures and incidents.
Sub-Processor: Company or service contracted by the Processor to assist or perform part of the data processing. Must be bound to the Processor by a contract ensuring equivalent protection standards.
Supplier (Technical or Support Supplier): Entity that provides services to the company (Processor or Controller) but does not have direct access to personal data or only processes anonymized data.

3. Data Processed

Depending on the contracted purpose, the platform may access data provided directly by the controllers, as well as data entered by the controllers. For example: first name, last name, national tax identification number, phone number, email, work address, residential address, etc.

4. Purposes

We use your data to:

Provide and improve our AI call services: Data is processed to offer and enhance the features of our services, products and platform for you, ensuring compliance with the law and good information security practices.
Processing of sensitive personal data: Sensitive personal data that may be unintentionally collected during call recording is processed to ensure compliance with legal and contractual obligations, ensure service quality, and protect the physical integrity and rights of those involved.
Google API integrations (Google Calendar): Talkover offers optional integration with third-party services such as Google Calendar to automate scheduling processes. When authorized by the client, Talkover may access data such as event names, time availability and calendar details to enable the integration.
Development and improvement of models and features: Call audio, transcriptions and metadata derived from use of the platform may be used to develop, train, evaluate and improve Talkover's models, resources and features, following prior removal or replacement of direct identifiers. The conditions, safeguards and opt-out procedure for this purpose are detailed in item 5.1 of this Policy.

Talkover declares, in accordance with Google's Limited Use Policy, that this application complies with Google API limited use requirements, including secure use, access and storage of data, without sharing with third parties, and exclusively for the stated functionality.

No data obtained via Google Calendar will be:

Shared with third parties
Used for advertising purposes
Permanently stored without legal basis
Used in ways inconsistent with the functionalities described in this policy

5. Call Recording and Transcription

Calls made using Talkover Agents may be recorded (recordings may be stored by Talkover for audit purposes only) and automatically transcribed. Conversations that occur outside the system (such as transferred calls, subsequent calls made without the Talkover agent, etc.) are not recorded or transcribed.

5.1 Use for Model Development and Improvement

The controller, as the party responsible for processing decisions, authorizes the use of call audio, transcriptions and derived metadata for the development, training, evaluation and improvement of models, resources and features, by Talkover and its sub-processors, subject to the following safeguards:

Use occurs following prior removal or replacement of data subjects' direct identifiers, so that they cannot be identified in the resulting artifacts.
Identifiable call content is not disclosed to third parties.
The data is not used for advertising purposes, nor sold.
The resulting models and features are not owned by the controller, and their use is not restricted to it.
Sensitive data unintentionally captured is excluded from the scope of this purpose whenever identified.
This purpose does not apply to data obtained through third-party API integrations, such as Google's, in accordance with the Limited Use Policy described in item 4.

Right to object: the controller may request in writing, at dpo@talkover.ai, that its account be excluded from this purpose. The request takes effect within 30 (thirty) days and does not apply retroactively to artifacts already produced, from which direct identifiers have already been removed.

It is the controller's responsibility to inform data subjects of this purpose and to have an adequate legal basis for it, reflecting it in its own privacy policy.

6. Automated Decisions and Right to Review

Artificial Intelligence interactions may include automated decision-making in accordance with the texts entered by the controller in the agent's knowledge base during its creation.

7. Sensitive Data

Talkover does not intentionally collect sensitive data. When such data is incidentally collected, it may be processed under the following circumstances:

To comply with legal, regulatory or contractual obligations, such as audit, inspection, or sector standards compliance requirements.
If the data is necessary for the performance or negotiation of a contract between the parties, even if collected without direct intent, it may be used to ensure rights and obligations.
If the data is relevant to ensure the safety of the data subject or third parties (e.g., in cases of emergency, threat or accident), its use is permitted.
Data may be used for the defense of company rights in litigation or proceedings, including documentary evidence.

8. Data Sharing

We may share your information with:

Service providers and sub-processors: Processed data may be shared with suppliers and sub-processors that support the system's optimal operation. We will only share with third parties who comply with applicable data protection regulations and ensure data security.
Authorities: When required by a legal order or applicable law, we will be obligated to share the requested information.
Business partners: We may occasionally share your personal data with partners and suppliers, who may or may not act on our behalf, in providing services strictly necessary for the operation, maintenance and improvement of our platform's features.

We do not sell your personal data.

9. International Transfers

If transferring your data outside your home country is necessary for the activities and purposes described, we will only do so in compliance with applicable data protection law, and only where the recipient is located in a country with an adequate level of data protection.

With whom: suppliers and sub-processors
What data: Texts and calls exchanged between agents and users / Personal data processed to perform the services
Purpose: Automatically generate responses to customers, store and process data, and communicate with contacts through calls

10. Information Security

We implement industry-standard security measures. Talkover adopts adequate technical and organizational measures to protect data:

Adoption of preventive security measures, such as two-factor authentication and strong passwords
A reliable electronic identification system for website access
Maintaining records of who accesses our website and uses our services to prevent fraud
Allowing only authorized persons to access your information
Periodic audits to certify that our environment is secure

If significant risks or harm to your rights are identified, you will be notified as soon as possible and the incident will be reported to the relevant supervisory authority within the legal deadlines. If you identify or become aware of any activity that compromises the security of your personal data, contact our DPO immediately at: dpo@talkover.ai.

11. Data Retention

Processed data, including recordings and transcriptions, is stored for the contracted period. Upon contract termination, data is retained for 90 days.

12. Your Rights

You may exercise your rights by contacting our Data Subject email: dpo@talkover.ai. Requests will be responded to within 15 days.

Our Privacy Notice may be updated periodically. We recommend that you visit this page regularly to stay informed of any changes.

13. Tracking Cookies

We use cookies to improve website functionality. For more details, see our Cookie Policy.

You may opt out of Google Analytics services using the opt-out feature. You can disable cookies in your browser settings, but some features may not work correctly.

Scope: The use of cookies for behavioral analysis and third-party advertising applies exclusively to your browsing on our public website. These practices do not extend to data processed within the Talkover platform after login and, under no circumstances, apply to information obtained through third-party API integrations, such as Google.

14. Limitation of Liability

All information (including the Software and Content) provided on the Site is provided "as is" and "as available", without warranty of any kind, express or implied, including but not limited to implied warranties of merchantability or fitness for a particular purpose.

15. Updates

We may update this Privacy Policy. We recommend that you visit this page periodically to check for possible changes. If significant changes are made, we will publish a new Privacy Policy.

Applicable Law: This document is governed by and must be interpreted in accordance with applicable law.

16. Contact

For privacy-related questions, please contact us:

Email for Privacy Policy requests: dpo@talkover.ai
Email for system usage questions: suporte@talkover.ai
Website: www.talkover.ai