Privacy policy

Data controller

Rispondly, Florence, Italy. Contact: ciao@rispondly.com.

This English text is a courtesy translation: the Italian version prevails.

Data we process

For our customers (the businesses): company and billing details, the connected phone number, and the price list and opening hours provided to build the assistant.

For callers: the calling number, the call audio during the conversation, the transcript of the call and the details given by voice for the booking (name, service, day, time, phone).

For people who leave their number in the form on the site: name, business name, phone number and, if given, city and sector. We use them only to write to you on WhatsApp and answer your questions, at your request.

For people who try the demo line: if you agree out loud during the call, we write to you on WhatsApp at the number you are calling from. There are two possible messages, each one only with your yes: the confirmation of the trial appointment and one message asking how it went. If you reply, your answer is read by us at Rispondly. No other messages follow, and you can ask us at any time to delete your number by writing to ciao@rispondly.com.

Purpose and legal basis

Running the service that answers phone calls and written messages and takes bookings on behalf of the customer business (performance of the contract). Rispondly acts as the processor on behalf of the customer business, which is the controller of its own clients' data.

Callers are told at the beginning of the call that they are speaking to a virtual assistant.

Retention

Call audio is kept for 30 days by default. Every customer business can choose 7, 30 or 90 days, or ask us not to record at all: once that time has passed the audio is deleted automatically from our servers.

Transcripts, written conversations, bookings and messages are kept for the duration of the contract. After cancellation, all data is deleted within 30 days.

The data left in the form on the site is deleted within 12 months if you do not become a customer, or sooner if you ask us.

Processors

To run the service we rely on selected suppliers, appointed as processors under article 28 of the GDPR: voice and transcription platforms, language models for the written replies, telephony and SMS carriers, messaging services for the notifications to the owner, online calendars (only when they are connected), email delivery services and server providers.

The servers of the service are in data centres in the European Union, in Germany. Where a supplier processes data outside the Union, the transfer relies on the standard contractual clauses of the European Commission, except Telegram for the notices to the owner (see Written conversations).

The current list of suppliers, with name, purpose and country, is in the panel for client businesses and is sent to anyone who asks at ciao@rispondly.com.

Google Calendar data

If a client business connects its Google Calendar from the panel, Rispondly asks for three permissions: to see the availability of the calendars (calendar.events.freebusy) so it knows when the business is already busy, to see the list of calendars (calendar.calendarlist.readonly) so the business can pick one, and to create, change or delete events (calendar.events) so the appointments taken by the assistant are written into the calendar. Rispondly does not ask for permission to read the contents of the events.

From the calendar we read only the busy periods (start and end times), through Google's free/busy query, and the names of the calendars the business can write to, so that it can pick one in the panel. We do not read the titles, descriptions, attendees or locations of the events already in the calendar.

We use this data only to offer free times to callers and to keep the calendar in line with the bookings. We do not sell it, we do not use it for advertising, and nobody at Rispondly reads it, except with the business's consent, for security reasons or when the law requires it.

Who receives it. During a call, the busy periods of the day the caller asks about are passed to the provider that runs the voice assistant, so that it can say which times are free: ElevenLabs (voice agent platform), which runs the Google Gemini language model for us, or OpenAI (voice model), depending on the line. They receive only those start and end times, under a data processing agreement, keep them in the conversation logs for at most 30 days and do not use them to train their models. The encrypted access token is stored on our servers at netcup in Germany. We do not transfer or disclose Google user data to anyone else, unless the law requires it.

How we protect it. The access token is encrypted with AES-256-GCM, the key is kept apart from the database and the token is never sent to the browser. Every connection, to Google, to our servers and to the providers, is encrypted with TLS. The busy periods are kept in memory only for the length of the call and are not saved in our database. Each business sees only its own data in the panel, and access to the servers is limited to Rispondly's administrator.

Artificial intelligence. Data obtained through Google Workspace APIs, whether raw, aggregated, anonymised or derived, is not used to develop, improve or train generalised or non-personalised artificial intelligence or machine learning models, neither by Rispondly nor by the providers listed above.

The business can disconnect the calendar at any time from the panel (Settings, Calendar), in which case we also delete the token, or revoke access from myaccount.google.com/permissions: from then on we can no longer read anything.

Rispondly's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Written conversations: website chat, Instagram and Messenger

A customer business can also switch the virtual assistant on for written messages: in the chat on the business's website, in the Direct messages of its Instagram professional account and in the Messenger messages of its Facebook Page. The assistant answers on the business's behalf. For these conversations the controller is the business you are writing to, and Rispondly processes the data as a processor (article 28 of the GDPR), only to run the service and on the business's instructions. If you write to Rispondly itself, for example to the Instagram account @rispondly or to the Rispondly Facebook Page, the controller is Rispondly.

Website chat. We store the messages, the page you wrote from and a random code that identifies the conversation. The code is created when you send your first message, and your browser keeps it only in the tab's session storage (sessionStorage): no cookies and no persistent browser storage. In the same session storage the chat also keeps whether its window was open and the first other site that led you there, which is sent to us only with your first message. We store your name and phone number only if you write them yourself, for example to book. While you type, the owner can see that you are typing, but not the text before you send it.

After your first message, so that the business knows who it is talking to, we also store: the pages of the site you open during the chat (address without parameters and title, the last ten), the first other site that led you there (address without parameters), your browser's language and time zone, a rough screen width class (small, medium or large), the type of device, the browser and the operating system as read from the User-Agent header, the approximate country and city, and your IP address partly masked (for IPv4 without the last number, for IPv6 only the first 48 bits). Country and city are derived from the IP address with a database kept on our own servers (IP Geolocation by DB-IP): the address is not sent to anyone. Before your first message we store none of this, and we do not use device fingerprinting. The full IP address is not stored with the conversation: it stays in memory for a few minutes for the limits against abuse and is written to the security log only when a request goes over those limits.

Instagram. We store the identifier Instagram assigns to you for that account, the name, username and profile picture that Instagram provides, and the messages of the conversation, including those the owner writes directly in the Instagram app. The owner sees your name and picture in the panel, with a link to your Instagram profile.

Messenger. We store the identifier Messenger assigns to you for that Page, the first name, last name and profile picture that Facebook provides, and the messages of the conversation, including those the owner writes from the Page's inbox. The owner sees your name and picture in the panel.

To connect Instagram or Messenger we store the id and name of the business's account or Page and an access token, encrypted with AES-256-GCM.

Photos, videos, voice messages, stickers, shared posts and story mentions that you send are not downloaded and the assistant does not see them: the conversation only keeps a line saying that you sent one, so the owner can look at it in the app.

If during the conversation you book or leave a message for the owner, the assistant records the appointment or the message with the name and phone number you wrote, and the conversation is linked to the customer record the business holds for that number. If the number is an Italian mobile, you may receive by SMS the confirmation of the appointment, a reminder the evening before and a notice if it is moved or cancelled.

Before you write, the website chat window says that you are writing to a virtual assistant based on artificial intelligence and not to a person; on Instagram and Messenger the assistant's first message says so. The owner can read every conversation and reply in person at any time. If the owner takes over a conversation and does not reply within 5 minutes, the assistant answers again.

Notices to the owner. Depending on the business's settings, the owner receives a notice on WhatsApp, on Telegram or by email when the assistant records a booking or a message, when you ask to talk to a person, when you write in a conversation the owner is handling and, if the owner chose so, for every new chat. The notice contains your name or username, your phone number if you wrote it, an excerpt of what you wrote or the details of the appointment, and the link to the conversation in the panel.

Recipients. The text of the conversation, with your name and phone number if we know them, is sent to OpenAI (OpenAI Ireland Ltd.) to write the reply (processing in the European Union and the United States, under the standard contractual clauses); OpenAI does not use this data to train its models. The pages you visited, your device and your approximate location are not sent to OpenAI. Instagram and Messenger messages travel through the platforms of Meta Platforms Ireland Ltd., which handles them under its own terms and privacy policy. Notices to the owner go through WhatsApp (Meta Platforms Ireland Ltd.), Telegram or Resend (email), and SMS through Twilio. Notices go through Telegram only if the owner chooses Telegram as the notice channel in the panel. Telegram (Telegram Messenger Inc., outside the European Union) does not sign standard contractual clauses with bot operators: for this channel the transfer rests on the business's own choice. If you prefer, you can ask the business to receive the notices on WhatsApp or by email. The conversations are stored on our servers at netcup in Germany.

Retention. Conversations are kept for as long as the contract between Rispondly and the business lasts and are deleted within 30 days of its end. Before then the business can delete them from its panel or ask Rispondly to delete them. On Instagram and Messenger a copy of the conversation stays in Meta's app in any case, under Meta's rules.

Your rights. For access, correction or deletion you can contact the business you wrote to, or ciao@rispondly.com, and we will pass the request on to the business. If the business disconnects Instagram or Messenger in its panel, the access token is deleted at once. If the person who connected the account removes the Rispondly app in the Instagram or Facebook settings, the connection is switched off and the token is deleted. If that person sends a data deletion request through Meta, we delete the connection and all its conversations, and our answer to Meta contains the address where the status of the request can be checked. Bookings and messages for the owner that came out of those conversations stay with the business, which is their controller.

Virtual assistant

At the beginning of every call the assistant states that it is a virtual assistant of the business. This disclosure cannot be turned off.

The assistant never asks for symptoms, diagnoses or medical documents, and it never processes payment data.

Your rights

You can ask at any time for access, correction, export or deletion of your data by writing to ciao@rispondly.com. You also have the right to lodge a complaint with the Italian data protection authority.

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