ColdCapture Privacy Policy

Effective Date: 01.07.2025

Last Updated: 01.07.2025

Contact: andrew@coldcapture.com

1. Introduction

This Privacy Policy explains how ColdCapture (“we,” “our,” “us”) collects, uses, stores, and shares your personal information when you use our services. By submitting your contact details, requesting a callback, or interacting with our platform, you consent to the data practices described below.

2. Information We Collect

We may collect and process the following types of personal information:

Your full name
Email address
Phone number
IP address
Browser and device metadata
Audio recordings and transcripts of phone calls
Time and date of form submissions
Website usage data collected through Google Analytics

3. Purpose of Data Processing

Your data is processed for the following purposes:

To deliver a one-time AI-assisted callback that you have explicitly requested
To record and transcribe calls for service delivery, quality monitoring, and performance improvement
To analyze traffic and usage on our website using Google Analytics
To ensure platform security and prevent abuse
To comply with legal obligations and regulatory requirements

4. Use of AI and Automated Systems

ColdCapture uses automated technologies and artificial intelligence tools, including systems developed by OpenAI, Synthflow, and ElevenLabs, to deliver callback services. The calls may be managed entirely by non-human systems. By submitting your information, you agree to the use of such automated systems to communicate with you.

5. Call Recording and Transcription

Calls made through our platform may be recorded and transcribed. These recordings and transcripts are used to fulfill your request, monitor quality, ensure compliance, and improve the accuracy and reliability of our AI agents. You should not use the callback feature if you do not agree to the recording or transcription of your call.

6. Legal Basis for Processing

We rely on the following legal bases under the General Data Protection Regulation (GDPR):

Your consent, for the collection and processing of contact data, voice data, and delivery of the callback
The necessity of processing for the performance of a contract, which in this context includes delivering the service you requested
Our legitimate interests, including service improvement, analytics, and security
Compliance with legal obligations, where applicable

7. Use of Third-Party Service Providers

We engage trusted third-party processors to provide core functionality of the service. These include:

OpenAI for language processing
ElevenLabs for synthetic voice delivery
Synthflow for call flow automation and orchestration
Claspo for form and popup handling
Google Analytics for web analytics and performance monitoring

Some of these providers may process your data outside of the European Union. Where applicable, data transfers are governed by Standard Contractual Clauses or equivalent safeguards in accordance with GDPR.

8. Data Retention

We retain your personal data only as long as necessary to fulfill its original purpose, or as long as required by law. This includes:

Call recordings and transcripts, stored for up to 30 days
Contact information, stored for up to 90 days unless you explicitly engage in further communication
IP address and browser metadata, stored for up to 60 days for compliance and security
Data related to scheduled meetings or opt-in follow-ups, stored as long as required to manage your request

You may request earlier deletion of your data at any time by contacting us.

9. Data Sharing

We do not sell, rent, or trade your personal data. Data is shared only with the above-listed service providers, our internal staff directly involved in delivering the service, or government authorities when legally required.

10. Your Rights Under GDPR

If you are located in the European Economic Area (EEA), you have the following rights under GDPR:

The right to access your personal data
The right to rectify inaccurate or incomplete data
The right to request deletion of your personal data
The right to withdraw consent at any time
The right to object to or restrict processing under certain conditions
The right to data portability
The right to lodge a complaint with your national data protection authority

To exercise any of these rights, email your request to andrew@coldcapture.com.

11. California Consumer Rights (CCPA)

If you are a resident of California, you may have the following rights under the California Consumer Privacy Act (CCPA):

The right to know what personal data we collect and how we use it
The right to request deletion of your data
The right to know whether your personal data has been disclosed and to whom
The right to opt out of the sale of your data (we do not sell personal data)

Requests may be submitted by contacting andrew@coldcapture.com.

12. Data Security

We implement appropriate technical and organizational security measures to protect your data. These include:

Encryption of sensitive data during transmission and at rest
Access control measures
Secure hosting infrastructure
Regular audits and internal access restrictions

13. Communication and Follow-Up

We will not send sales or marketing communications without your explicit consent. You will only receive additional calls, emails, or messages if you opt in—such as by scheduling a meeting, checking an additional consent box, or requesting follow-up communication.

14. Updates to This Privacy Policy

We may update this Privacy Policy at any time to reflect changes in the law or the services we offer. The latest version will always be posted on this page with the updated effective date. Your continued use of the service constitutes acceptance of any changes made.

15. Contact Information

If you have questions or concerns about this Privacy Policy or the handling of your data, please contact:

Email: andrew@coldcapture.com