Privacy Policy

Last Updated: August 15, 2024

Introduction

Welcome to Traincalling, a product of Midterm AB.

Midterm AB ("us", "we", or "our") operates https://www.traincalling.com (hereinafter referred to as "Service").

Our Privacy Policy governs your visit to https://www.traincalling.com, and explains how we collect, safeguard and disclose information that results from your use of our Service.

We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions ("Terms") govern all use of our Service and together with the Privacy Policy constitutes your agreement with us ("agreement").

Definitions

SERVICE means the https://www.traincalling.com website operated by Midterm AB.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

CLIENT refers to the company or individual who has engaged Traincalling for the purpose of using our AI-powered cold calling training platform.

AI AGENT refers to the artificial intelligence-powered virtual entity used in our Service to simulate potential customers or prospects for training purposes.

TRAINING SESSION refers to a simulated cold calling interaction between a User and an AI Agent on our platform.

Types of Data Collected

Traincalling collects several types of data to provide and improve our AI-powered cold calling training platform. Here's a detailed breakdown of the types of data we collect:

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Company name and job title
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as:

  • Your computer's Internet Protocol address (e.g., IP address)
  • Browser type and version
  • The pages of our Service that you visit
  • The time and date of your visit
  • The time spent on those pages
  • Unique device identifiers
  • Other diagnostic data

When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Training Session Data

As part of our core service, we collect data related to your training sessions:

  • Audio recordings of your interactions with AI agents
  • Transcripts of these interactions
  • Performance metrics and scores
  • Feedback provided by AI agents
  • Your responses to post-session surveys or feedback requests

Location Data

We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Service and to improve and customize our Service.

You can enable or disable location services when you use our Service at any time through your device settings.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies: We use Session Cookies to operate our Service.
  • Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies: We use Security Cookies for security purposes.
  • Analytics Cookies: We use Analytics Cookies to understand how you interact with our Service and to improve our offerings.

Payment Data

If you make purchases through our Service, we may collect and store information about your payment methods, including credit card numbers, billing addresses, and other payment details. However, actual payment processing is handled by our third-party payment processors, and we do not store complete credit card information on our servers.

Platform Data

Traincalling is an AI-powered cold calling training platform that facilitates conversations between users and AI agents. To enable our service, we process and store certain information related to the training sessions, AI agents, user accounts, and performance metrics. We act as a data processor on behalf of our customers (Clients).

  1. AI Agents When we create AI agents for our platform, we store the configuration settings, prompts, and any training data or templates used to build the agent's conversational abilities. This may include sample phrases, knowledge base content, dialog flows, and AI model parameters. AI agent data is kept for as long as it's relevant for providing our Service.

  2. Training Sessions To provide our AI-powered training service, we process audio in real-time to convert speech to text, apply natural language understanding, and generate responses. Training session data we collect includes:

    • Session participants: User identifier and AI agent identifier
    • Session metadata: Start and end times, duration, session status
    • Session media: Recordings of the session audio (if enabled by the Client)
    • Session transcripts: Speech-to-text transcriptions of the session audio
    • Session logs: Details on the conversation flow, AI responses, and outcomes
    • Performance metrics: Scores, ratings, and other evaluation data

    Training session recordings, transcripts, and logs may be retained to help train and improve our AI models, in accordance with applicable laws. Retention periods depend on the Client's configuration, and data is deleted upon request.

  3. User Accounts We securely store necessary credentials for user accounts, such as usernames, encrypted passwords, and user roles. These credentials are encrypted and accessible only to the Traincalling systems that require them to operate the service. Account data is deleted upon user or Client request, or when no longer needed.

  4. Performance Analytics To provide insights and improve our service, we store and process aggregated performance data. This includes:

    • Individual user performance trends
    • Team or organization-level performance metrics
    • AI agent performance and effectiveness data
    • Usage statistics and patterns

    This data is used to generate reports, improve our AI models, and enhance the overall training experience. Aggregated data may be retained indefinitely, but individual data points can be deleted upon request.

Use of Data

Traincalling uses the collected data for various purposes:

  • to provide and maintain our Service;
  • to notify you about changes to our Service;
  • to allow you to participate in interactive features of our Service when you choose to do so;
  • to provide customer support;
  • to gather analysis or valuable information so that we can improve our Service;
  • to monitor the usage of our Service;
  • to detect, prevent and address technical issues;
  • to fulfill any other purpose for which you provide it;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
  • to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information;
  • in any other way we may describe when you provide the information;
  • for any other purpose with your consent.

Retention of Data

Traincalling will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Traincalling will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Midterm AB will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

We may disclose personal information that we collect, or you provide:

Disclosure for Law Enforcement

Under certain circumstances, Midterm AB may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Business Transaction

If Midterm AB or its subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

Other cases

We may disclose your information also:

  • to our subsidiaries and affiliates;
  • to contractors, service providers, and other third parties we use to support our business;
  • to fulfill the purpose for which you provide it;
  • for the purpose of including your company's logo on our website;
  • for any other purpose disclosed by us when you provide the information;
  • with your consent in any other cases;
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Midterm AB, our customers, or others.

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at support@traincalling.com.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you.
  • The right of rectification.
  • The right to object.
  • The right of restriction.
  • The right to data portability.
  • The right to withdraw consent.

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

According to CalOPPA, we agree to the following:

  • Users can visit our site anonymously.
  • Our Privacy Policy link includes the word "Privacy" and can easily be found on the page specified above on the home page of our website.
  • Users will be notified of any Privacy Policy changes on our Privacy Policy Page.
  • Users are able to change their personal information by emailing us at support@traincalling.com.

Our Policy on "Do Not Track" Signals:

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:

  • What personal information we have about you. If you make this request, we will return to you:

    • The categories of personal information we have collected about you.
    • The categories of sources from which we collect your personal information.
    • The business or commercial purpose for collecting or selling your personal information.
    • The categories of third parties with whom we share personal information.
    • The specific pieces of personal information we have collected about you.
    • A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
    • A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.

  • To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.

  • To stop selling your personal information. We don't sell or rent your personal information to any third parties for any purpose. We do not sell your personal information for monetary consideration. However, under some circumstances, a transfer of personal information to a third party, or within our family of companies, without monetary consideration may be considered a "sale" under California law. You are the only owner of your Personal Data and can request disclosure or deletion at any time.

If you submit a request to stop selling your personal information, we will stop making such transfers. Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.

To exercise your California data protection rights described above, please send your request(s) by email to support@traincalling.com.

Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

You can request an up-to-date list of third-party Service Providers by emailing us at support@traincalling.com. We provide a non-comprehensive list of our Service Providers below.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

  • Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

  • Vercel Analytics: Vercel Analytics is a web analytics service provided by Vercel Inc. For more information on the privacy practices of Vercel, please visit their Privacy Policy page: https://vercel.com/legal/privacy-policy

  • PostHog: For more information about PostHog, please visit their Privacy Policy: https://posthog.com/privacy

CI/CD tools

GitHub: GitHub is provided by GitHub, Inc. GitHub is a development platform to host and review code, manage projects, and build software. For more information on what data GitHub collects and how the protection of the data is ensured, please visit GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.

Payments

We provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

  • Stripe: Their Privacy Policy can be viewed at: https://stripe.com/us/privacy

Links to Other Sites Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. Children's Privacy Our Services are not intended for use by children under the age of 13 ("Children"). We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers. Changes to This Privacy Policy We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Contact Us If you have any questions about this Privacy Policy, please contact us:

By email: support@traincalling.com