Politique de Confidentialité

Handlo AI, Inc. · Last Updated: June 27, 2026 · Effective Date: June 9, 2026

1. Introduction

Handlo AI, Inc. ("Handlo," "we," "us," or "our") is a Delaware corporation that provides an AI-powered phone answering and lead capture service accessible at handlo.ai (the "Service"). This Privacy Policy explains how we collect, use, disclose, and protect information about you when you visit our website or use our Service.

In this Policy, "personal data" (under the GDPR / UK GDPR) and "personal information" (under U.S. state privacy laws such as the CCPA/CPRA) refer to the same thing: information relating to an identified or identifiable individual.

By accessing our website or using our Service, you agree to this Privacy Policy. If you do not agree, please do not use our Service.

2. Our Role: Controller and Processor

Handlo plays two distinct roles depending on the data involved:

• As a "controller" of account, website, and billing data — the personal data of our customers, their team members, and website visitors — we determine how and why that data is processed, and the rights described in this Policy can be exercised directly with us.
• As a "processor" of caller and CRM-contact data — the personal data captured when our AI answers calls on a customer's behalf, and the contact records stored in a customer's CRM — our customer is the controller. We process that data only on the customer's documented instructions under our Data Processing Addendum. If you are a caller or contact and wish to exercise privacy rights over data Handlo holds as a processor, please contact the business you interacted with; we will assist that business as required by our DPA.

3. Information We Collect

3.1 Information You Provide Directly

• Account Registration: Email address, password (stored in encrypted form), display name, and language preference.
• Business Profile: Business name, type, industry, services offered, website URL, business hours, and timezone.
• AI Configuration: Custom instructions, greeting templates, call handling preferences, and knowledge base content (including uploaded files, website URLs, and manually entered FAQ content).
• Billing Information: Payment method details processed by Stripe, Inc. We do not store full card numbers on our servers.
• Communications: Any messages or support requests you send us, including via our support chat widget.

3.2 Information Collected Automatically Through the Service

• Call Data: When your AI agent receives or handles a phone call, we collect: caller phone number, caller name (if provided), caller email (if provided), call direction, call duration, call category, lead score, outcome tag, and after-hours flag.
• Call Recordings: Audio recordings of calls handled by your AI agent, subject to applicable consent requirements (see "Call Recording Consent" below).
• Transcripts: Verbatim text transcripts of calls, stored as structured data including speaker turns.
• AI-Generated Data: Post-call summaries, structured data extracted from calls, action-needed flags, and lead follow-up drafts generated by our AI.
• Lead and CRM Data: Contact records including caller phone, name, email, lead stage, lead score, deal value, notes, appointment records, and stage change history.
• Usage Data: Pages visited, features used, session duration, browser type, IP address, device type, and referring URLs.
• Log Data: Server logs, error reports (via Sentry), and API request logs.

3.3 Information from Third Parties

• Phone Providers: Phone number details and call metadata from Twilio and Telnyx.
• Calendar Integration: Appointment details from Google Calendar when you connect your Google account.
• CRM Integrations: Contact and deal data synced from GoHighLevel or HubSpot when you enable those integrations.
• Spam Detection: Phone number reputation data from IPQualityScore (IPQS) (available on Growth and Business tiers) and Twilio Lookup.

3.4 Widget Data Collection

When a business embeds the Handlo web widget on their website, visitors who interact with the widget may provide their name, phone number, and email address before a call is connected. This data is collected on behalf of the business (the Handlo customer) and is subject to that business's own privacy policy. Handlo processes this data solely to initiate and route the call and to pre-populate the caller's lead record.

3.5 Google Calendar and Google Drive Data

When you connect your Google account, Handlo requests only the narrowest scopes required for the features you enable:

• Google Calendar (https://www.googleapis.com/auth/calendar.events) — to read your availability and to create, reschedule, or cancel the appointment events that your AI agent books on your behalf. We request event-level access only, not full-calendar, settings, or contact access, and we access only the calendar you connect.
• Google Drive (https://www.googleapis.com/auth/drive.file) — a per-file scope that lets you choose specific files through Google's file picker to add to your knowledge base. Handlo can access only the files you explicitly select; it cannot see, list, or read any other file in your Drive.

We use this data solely to provide the calendar-booking and knowledge-import features you enable, store it in encrypted form, and never use it for advertising or to train generalized AI models. Handlo'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. You can revoke Handlo's access at any time from your Google Account permissions page or from within the Handlo dashboard.

4. How We Use Your Information

We use your information to:

• Provide the Service: Power your AI phone agent, process calls, generate transcripts and summaries, manage leads, and send notifications.
• Improve the Service: Analyze aggregated and de-identified usage patterns, troubleshoot issues, and develop new features.
• Billing and Account Management: Process payments, manage subscriptions, and send invoices and receipts.
• Communications: Send transactional emails (account activation, trial reminders, billing notifications), WhatsApp lead alerts, Telegram notifications, and respond to support requests.
• Compliance: Maintain consent records, enforce data retention policies, and comply with applicable law.
• Security: Detect fraud, prevent abuse, and protect the integrity of our platform.

We do not sell your personal data or your callers' personal data, and we do not share it for cross-context behavioral advertising. We do not use call recordings or transcripts to train general-purpose AI models without your explicit consent.

5. Legal Bases for Processing (GDPR / UK GDPR)

Where the GDPR or UK GDPR applies, we rely on the following legal bases:

Where we rely on legitimate interests, you may object to that processing as described below. For caller and CRM-contact data that we process as a processor, the controller (our customer) is responsible for establishing the legal basis.

6. How We Share Your Information

We share information only as set out below. The vendors that process personal data on our behalf are maintained in our current Sub-processor Register, which is incorporated by reference into our DPA.

We require all service providers to protect your information consistent with this Policy and applicable law.

We may also disclose information: (a) to comply with legal obligations or respond to lawful requests; (b) to enforce our Terms of Use; (c) to protect the rights, property, or safety of Handlo, our users, or others; or (d) in connection with a merger, acquisition, or sale of assets (with advance notice to affected users).

7. International Data Transfers

The bulk of personal data processed by the Service — our primary database and file storage (Supabase), background worker (Railway), caching (Upstash), and product analytics (PostHog) — is hosted in the European Union. Some sub-processors are located in the United States, as identified in the Sub-processor Register.

Where personal data is transferred from the EEA, UK, or Switzerland to a country not recognized as providing adequate protection (including the United States), we rely on the European Commission's Standard Contractual Clauses (SCCs), supplemented by the UK International Data Transfer Addendum and, for Switzerland, the Swiss addendum to the SCCs. A copy of the relevant transfer mechanism is available on request at privacy@handlo.ai.

8. Data Retention

We retain your data for as long as your account is active. After that:

• Call recordings and transcripts are retained in accordance with the data-retention period you configure in your dashboard (default: 365 days), after which they are deleted or anonymized.
• Account and business data are deleted within 30 days of account closure.
• Billing records are retained for 7 years as required by applicable tax and financial regulations.
• Routine backups are purged on their normal rotation cycle.

You can configure your data retention policy within the Service dashboard, and you can request deletion of specific data by contacting us at privacy@handlo.ai.

9. Your Privacy Rights

9.1 All Users

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your data, subject to legal retention requirements.
• Portability: Request your data in a structured, machine-readable format.

9.2 European Economic Area (GDPR)

If you are located in the EEA, you have additional rights under the General Data Protection Regulation:

• Right to Object: You may object to processing based on legitimate interests.
• Right to Restrict: You may request restriction of processing in certain circumstances.
• Right to Withdraw Consent: Where we rely on consent, you may withdraw it at any time without affecting prior processing.
• Supervisory Authority: You have the right to lodge a complaint with your local data protection authority.

9.3 United Kingdom (UK GDPR)

If you are located in the United Kingdom, you have equivalent rights under the UK GDPR and the Data Protection Act 2018, and you may lodge a complaint with the UK Information Commissioner's Office (ICO). Transfers out of the UK are made under the UK International Data Transfer Addendum.

9.4 Switzerland (FADP)

If you are located in Switzerland, you have equivalent rights under the Swiss Federal Act on Data Protection (FADP), and you may contact the Swiss Federal Data Protection and Information Commissioner (FDPIC). Transfers out of Switzerland are made under the Swiss addendum to the SCCs.

9.5 California (CCPA / CPRA)

California residents have the right to: (a) know what personal information is collected, used, and disclosed; (b) delete personal information we hold about them; (c) correct inaccurate personal information; (d) access and obtain a portable copy of their personal information; (e) opt out of the sale or sharing of personal information; and (f) limit the use of sensitive personal information; and to receive equal service and price (non-discrimination).

We do not sell or share personal information (including for cross-context behavioral advertising), so there is no "Do Not Sell or Share My Personal Information" action required. We use any sensitive personal information (such as voice recordings — see "Voice and Biometric Data" below) only to provide and secure the Service and for the other purposes permitted under the CPRA, so no separate "Limit the Use of My Sensitive Personal Information" action is required.

A Notice at Collection is provided by the categories of personal information described in "Information We Collect" above, the purposes described in "How We Use Your Information," and the retention periods in "Data Retention."

9.6 How to Exercise Your Rights

To exercise any of these rights, contact us at privacy@handlo.ai. We will verify your identity using the information associated with your account or request before acting. You may use an authorized agent to submit a request on your behalf, provided the agent supplies proof of authorization and we can verify your identity. We respond within the timeframes required by law — generally within 30 days (GDPR/UK/Swiss) or 45 days (California, extendable to 90 days where permitted, with notice).

9.7 Service Provider Access (Support Sessions)

To resolve a support ticket you raise, a Handlo support agent may access your account in read-only mode. This access:

• Is gated by a written reason and (typically) your ticket reference; both are recorded in our audit log.
• Lasts at most 15 minutes per session and ends automatically.
• Cannot make any change to your data (writes are blocked at the application layer).
• Is recorded in audit_events and visible to you in your account's audit log.
• When a support agent ends a session, we send you an in-app notification and email.

If you did not contact Handlo support but receive a session-ended notification, contact privacy@handlo.ai immediately.

10. Call Recording Consent

Call recording laws vary by jurisdiction. Handlo provides configurable consent disclosure rules to help you comply:

• United States: Many U.S. states require one-party or two-party consent before recording. Your AI agent can be configured to announce recording at the start of each call.
• European Union / UK: The GDPR requires a valid legal basis (typically consent) before recording personal data. For EEA callers, the Service does not record audio unless recording consent is satisfied. Your AI agent should announce recording and obtain verbal consent.
• Other Jurisdictions: Specific rules apply. You are responsible for ensuring your AI agent complies with local recording laws in all jurisdictions where you operate.

Handlo logs consent status per call. You remain solely responsible for configuring your agent appropriately and for compliance with applicable recording consent laws.

11. Voice and Biometric Data

The Service records and transcribes calls. It does not create a voiceprint or other biometric identifier and does not perform voice biometric identification. Even so, some U.S. states (including Illinois under BIPA, Texas under CUBI, and Washington) treat voice recordings as biometric data requiring specific consent and handling, and Washington's My Health My Data Act may apply to certain consumer-health contexts. The call recording announcements built into the Service assist with disclosure, but they are a disclosure aid and not a substitute for any written consent the law may require. You are responsible for ensuring your use of the Service complies with applicable biometric privacy laws in your jurisdiction.

12. Automated Decision-Making

The Service uses automated processing to support your decisions — for example, scoring leads (hot/warm/cold), categorizing calls, identifying returning callers, and tagging call outcomes. These are decision-support signals to help you prioritize follow-up; they do not by themselves produce legal or similarly significant effects on a data subject. If you believe an automated output is inaccurate, you can review and override it in your dashboard, and you may contact privacy@handlo.ai. For caller and CRM-contact data, requests relating to automated processing should be directed to the business (the controller); Handlo will assist as set out in its DPA.

13. Cookies and Tracking

Our website and app use cookies and similar technologies for authentication and session management (essential), consent-gated product analytics, and storing your language and theme preferences. For full details — including the specific cookies we set, their purpose and retention, and how to manage your consent — see our Cookie Policy. You can manage non-essential cookies through our cookie banner; disabling certain cookies may affect Service functionality.

14. Children's Privacy

Our Service is intended for businesses and is not directed to children. We do not knowingly collect personal information from children under 13 (in line with COPPA), and our Terms require account holders to be at least 18. If we learn we have collected personal information from a child in violation of applicable law, we will delete it promptly.

15. Security

We implement commercially reasonable technical and organizational measures to protect your information, including:

• Encryption of data in transit (TLS) and at rest (AES-256).
• Role-based access controls limiting employee access to personal data.
• Signed, time-limited URLs for accessing call recordings.
• Audit logging and regular security monitoring and error tracking via Sentry.

No security system is impenetrable. In the event of a data breach, we will notify affected individuals and the relevant supervisory authorities as required by applicable law. Where a breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay. The specific security measures we apply as a processor are set out in our Data Processing Addendum.

16. Changes to This Policy

We may update this Policy periodically. We will revise the "Last Updated" date above and, for material changes, notify you by email or by posting a notice in the Service. A summary of material changes and prior versions is available on request at privacy@handlo.ai. Your continued use of the Service after changes take effect constitutes acceptance of the updated Policy.

17. Language

This Policy is published in English, which is the binding version. Any translation is provided for convenience only; if there is a conflict, the English version controls.

18. Contact Us

For privacy-related questions, requests, or complaints:

Handlo AI, Inc. Attn: Privacy 131 Continental Drive, Suite 305 Newark, DE 19713 USA

Email: privacy@handlo.ai Website: handlo.ai