Privacy Policy of the “Doganswer” Application

1. Scope of the Policy

This Privacy Policy (hereinafter: the “Policy”) contains information on the processing of your personal data in connection with the use of the “Doganswer” application (hereinafter: the “Application”) available at: https://doganswer.com/ (hereinafter: the “Website”).

The Policy covers all three places in which you use the Application:

1. the Website at https://doganswer.com,
2. the web panel at https://app.doganswer.com,
3. the Doganswer mobile app for Android and iOS.

Any capitalised terms not otherwise defined in the Policy have the meaning given to them in the Application Terms or in the Newsletter Terms, available at: https://doganswer.com/en/terms/ and https://doganswer.com/regulamin-newslettera (in Polish).

This is an English translation of the Polish original available at https://doganswer.com/polityka-prywatnosci/. In case of any discrepancies, the Polish version prevails.

2. Controller of personal data

The Controller of your personal data is DOGTRONIC LABS spółka z ograniczoną odpowiedzialnością with its registered office in Lublin (registered office address: ul. Hajdowska 43C, 20-231 Lublin, Poland), entered in the register of entrepreneurs of the National Court Register kept by the District Court Lublin-East in Lublin with its seat in Świdnik, 6th Commercial Division of the National Court Register, under KRS number: 0001229537, holding NIP (tax identification number): 9462765575, REGON (statistical number): 544273828, with share capital of PLN 100,000.00 (one hundred thousand zlotys) (hereinafter: the “Controller”).

DOGTRONIC LABS spółka z ograniczoną odpowiedzialnością with its registered office in Lublin acts as the Controller with respect to the data of Customers which they have provided to the Controller under the Agreement (including in the process before its conclusion, during its conclusion and after its conclusion).

With respect to data provided to DOGTRONIC LABS spółka z ograniczoną odpowiedzialnością with its registered office in Lublin by a Customer acting as the controller of such data, DOGTRONIC LABS spółka z ograniczoną odpowiedzialnością with its registered office in Lublin acts as a processor. This applies in particular to the data of persons calling the Customer and data from the Customer’s contact book. The obligations of DOGTRONIC LABS spółka z ograniczoną odpowiedzialnością with its registered office in Lublin as a processor and the rights of the persons whose data are processed in this way are set out in detail in Appendix No. 1 to the Terms – the Data Processing Terms.

3. Contacting the Controller

In all matters relating to the processing of personal data, you can contact the Controller by e-mail at: [email protected].

You send every request described in section 15 (Your rights) and in section 16 (Deletion of the account and data) to the same address.

4. Personal data protection measures

The Controller applies modern organisational and technical safeguards to ensure the best possible protection of your personal data and guarantees that it processes them in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter: the “GDPR”), the Polish Act of 10 May 2018 on the protection of personal data and other personal data protection laws.

Access to the data in your account is limited to authorised employees and associates of the Controller, and only to the extent necessary to perform the task entrusted to them. The refresh token for the Google Calendar that you connect to your account is stored in encrypted form.

5. Information on the personal data processed

Using the Application requires the processing of your personal data. Below you will find detailed information on the purposes and legal bases of processing, as well as on the processing period and whether providing the data is mandatory or voluntary.

5.1. Conclusion and performance of the Agreement for the provision of the Service and registration of the Account

Personal data processed: first name and surname; e-mail address; telephone number; language; gender; other data provided by the Customer.

Legal basis: Art. 6(1)(b) GDPR (processing is necessary for the registration of the Account and the performance of the Agreement for the use of the Application concluded with the data subject, or in order to take steps prior to entering into it).

Providing the above personal data is a condition for registering the Account and concluding and performing the Agreement for the provision of the Service (providing them is voluntary, but failure to provide them will make it impossible to register the Account and to conclude and perform the Agreement).

Signing in with Google or Apple: if you create an account or sign in using the Google or Apple button, in the web panel or in the mobile app, we receive from that company your first name and surname (if you share them), your e-mail address and your account identifier. We do not store your profile picture, and we do not receive your Google or Apple account password. We use these data solely to create the account and to sign you in. To data from signing in with Google we apply the same rules as in points 11.3 and 11.4.

Processing period: until the limitation period for claims arising from the Agreement for the provision of the Service and the registration of the Account by the Customer as a digital service expires.

5.2. Handling of complaints

Personal data processed: first name and surname or company name; e-mail address; other data provided by the Customer.

Legal basis: Art. 6(1)(b) GDPR (processing is necessary for the performance of the Agreement and the exercise of the Customer’s rights under the Agreement). With respect to an Entrepreneur with the rights of a Consumer, also Art. 6(1)(c) GDPR (the Controller’s legal obligation arising from Articles 43k–43o in conjunction with Article 7aa of the Polish Consumer Rights Act).

Providing the above personal data is a condition for receiving a response to the complaint or for the exercise of the Customer’s rights under the Agreement.

Processing period: for the duration of the complaint procedure and, where the above rights of the Customer are exercised, until they become time-barred.

5.3. Conducting verification proceedings and handling appeals against decisions concerning illegal content

Personal data processed: first name and surname or name; contact details, including e-mail address.

Legal basis: Art. 6(1)(c) GDPR (processing is necessary for compliance with a legal obligation to which the Controller is subject, in this case providing a mechanism for notifying illegal content – Article 16 of Regulation 2022/2065 on a Single Market for Digital Services, hereinafter: the “DSA” – and handling complaints, Article 20 DSA).

Providing the above personal data is a condition for receiving a response to the notice or for the exercise of rights under the DSA.

Processing period: for the duration of the proceedings and, where the above rights are exercised, until they become time-barred.

5.4. Handling enquiries submitted by Customers

Personal data processed: first name; e-mail address; other data contained in the message to the Controller.

Legal basis: Art. 6(1)(f) GDPR (the Controller’s legitimate interest, in this case responding to the enquiry received).

Providing the above personal data is voluntary but necessary to receive a response to the enquiry.

Processing period: until an objection is effectively raised or the purpose of processing is achieved, whichever occurs first.

5.5. Fulfilment of tax obligations, including issuing VAT invoices and storing accounting records

Personal data processed: first name and surname or business name; address of residence or registered office; NIP (tax identification number).

Legal basis: Art. 6(1)(c) GDPR (a legal obligation to which the Controller is subject, arising from tax law).

Processing period: 5 years from the end of the year in which the tax payment deadline for the previous year expired.

5.6. Fulfilment of obligations relating to personal data protection

Personal data processed: first name and surname; contact details provided by the Customer (e-mail address, correspondence address, telephone number).

Legal basis: Art. 6(1)(c) GDPR (a legal obligation to which the Controller is subject, arising from personal data protection laws, including giving effect to the rights granted to you by the GDPR).

Processing period: until the limitation periods for claims relating to infringements of personal data protection laws expire.

5.7. Establishment, exercise or defence of legal claims

Personal data processed: first name and surname or business name; e-mail address; address of residence or registered office; PESEL number; NIP (tax identification number).

Legal basis: Art. 6(1)(f) GDPR (the Controller’s legitimate interest, in this case the establishment, exercise or defence of claims that may arise in connection with the performance of Agreements concluded with the Controller).

Processing period: until the limitation periods for those claims expire.

5.8. Analysis of your activity on the Website (doganswer.com)

Personal data processed: date and time of the visit; IP number of the device; type of the device’s operating system; approximate location; type of web browser; time spent on the Website; information about clicks; subpages visited and other actions taken on the Website. The web panel at https://app.doganswer.com and the mobile app do not use analytics tools.

Legal basis: Art. 6(1)(f) GDPR (the Controller’s legitimate interest, in this case obtaining information about your activity on the Website).

Processing period: until an objection is effectively raised or the purpose of processing is achieved.

5.9. Administration of the Application and the Website

Personal data processed: IP address; server date and time; information about the web browser; information about the operating system. The above data are recorded automatically in so-called server logs each time the Application is used (administration without the use of server logs and automatic recording would not be possible).

Legal basis: Art. 6(1)(f) GDPR (the Controller’s legitimate interest, in this case ensuring the proper functioning of the Application).

Processing period: until an objection is effectively raised or the purpose of processing is achieved.

5.10. Handling the contact form

Personal data processed: first name and surname; e-mail address; company name; telephone number; other data contained in the message to the Controller.

Legal basis: Art. 6(1)(f) GDPR (the Controller’s legitimate interest, in this case responding to the message sent).

Processing period: until an objection is effectively raised or the purpose of processing is achieved.

5.11. Conclusion and performance of the Agreement for the provision of the Newsletter or other Digital Content

Personal data processed: e-mail address.

Legal basis: Art. 6(1)(b) GDPR (processing is necessary for the performance of the Agreement for the provision of the Newsletter or Digital Content) and Art. 6(1)(f) GDPR (the Controller’s legitimate interest, in this case providing information about news and promotions available in the Application).

Processing period: until an objection is effectively raised, the purpose of processing is achieved or claims arising from that Agreement become time-barred, whichever occurs first.

5.12. Data processed in connection with the operation of the Assistant

Separately from the above, we process data generated while you use the telephone Assistant. They are described in detail in sections 7–12 of the Policy: call recordings and transcripts, Knowledge Base, notifications, plan counters, the connection with Google Calendar and Google Contacts, and the mobile app.

What we do not use these data for. We process data from calls, the Knowledge Base, contacts and the calendar solely to provide the Service to you. Beyond that, only to the extent necessary to:

1. ensure the security of the Application and detect abuse,
2. comply with a legal obligation, for example a request from a competent authority,
3. handle a request that you yourself submit to us,
4. settle the Service, for example count the minutes used.

Apart from these cases, we do not use these data for our own purposes. We do not train artificial intelligence models on them and we do not sell them. We do not use them for advertising or marketing.

AI providers: we use artificial intelligence providers with whom training models on the data transferred is disabled in the account settings or by contract.

One exception beyond our control: Twilio Inc., the operator of the telephone line and SMS, processes some data about calls and messages as an independent controller, for its own purpose of preventing abuse, spam and fraud. Twilio’s policy: https://www.twilio.com/en-us/legal/privacy.

6. Profiling

In order to create your profile for marketing purposes and to direct to you direct marketing tailored to your preferences, the Controller will process your personal data by automated means, including profiling them. However, this will not produce any legal effects concerning you or similarly significantly affect your situation.

The scope of the personal data profiled corresponds to the scope indicated in section 5.8 with respect to the analysis of your activity on the Website (doganswer.com) and the data you save in your Account.

The legal basis for processing personal data for the above purpose is Art. 6(1)(f) GDPR. Providing the above personal data is voluntary but necessary to achieve this purpose. The Controller will process personal data for profiling until an objection is effectively raised or the purpose of processing is achieved.

Call recordings, transcripts and Knowledge Base content are not used for profiling or for marketing.

7. Call recordings and transcripts

The Assistant answers calls forwarded from your telephone number. Every such call is recorded, and a transcript and summary are created from the recording.

What we save for each call: the caller’s number, the number that was called, the date and time, the duration, the language of the call, the recording, the full transcript, the summary and the subject of the call. If the caller is among the contacts saved in your account, we also save their name from those contacts.

Why: so that you know who called and what about, and so that you can listen to the call instead of calling back blindly.

Where you will see it: in the web panel and in the mobile app, in the Calls tab. For each call you can see who called and when, the summary, the full record of the conversation and a recording player.

Who sees it: you, after signing in to your account. Our team does not listen to recordings or read transcripts, unless you ask us for help with a specific matter, or security or a legal obligation requires it.

To whom we transfer it and why:

We do not use call data to train artificial intelligence models.

How long:

A call that you delete from the list in the Application stops being visible immediately, and its recording is erased at the latest within the 90-day cycle.

Legal basis: Art. 6(1)(b) GDPR with respect to your data (performance of the Agreement). With respect to the data of callers, we act as a processor on your instructions.

Who is the controller here: with respect to the data of persons who call you, you are the controller, and we process those data on your behalf. The rules are set out in the Data Processing Terms, i.e. Appendix No. 1 to the Terms. As the controller, you provide callers with full information about the processing of their data, for example on your website.

What the caller hears: the Assistant tells the caller that they are speaking with an AI Assistant and that the call is being recorded. You set the rest of the greeting yourself in the Assistant settings.

Demo version: we do not save calls to the demo number made available on the Website in any account or in our database, and we do not download their recording. Only a short summary is created from the record of the call, which we send via WhatsApp or by SMS to the number you called from. To this extent, we are the controller of the data. We automatically delete the copy of the call at the voice conversation provider (ElevenLabs) after 30 days. We do not use the number you called from for marketing without your separate consent.

8. Knowledge Base

In the Knowledge Base tab you enter information about your business that the Assistant uses during calls. You can add questions with ready answers, topic descriptions and tables, for example a price list, the scope of services or opening hours. The feature is available from the Professional plan.

What we do with this content: we save it in your account and convert it into a mathematical form (so-called vectors), which makes it possible to find the right fragment during a call. For this conversion we use a model made available through OpenRouter. The fragment that matches the caller’s question is passed to the Assistant conducting the call and may be read out loud.

What you are responsible for: you fill in the Knowledge Base yourself and you decide what goes into it. Do not enter your customers’ personal data or any information you do not want to share with callers. The Assistant may read out any content entered there.

What we do not do: we do not use Knowledge Base content to train models, we do not share it with other Customers and we do not use it for marketing purposes.

Legal basis: Art. 6(1)(b) GDPR (performance of the Agreement at your request).

How long: until you delete the entry or the account.

9. Notifications

After a call ends, we may send you a notification with a summary. You have four channels, and you turn each one on and off separately in your account settings:

What the notification contains: the caller’s number or their name from your contacts, the time of the call and its summary. We do not send the recording through any of these channels; you listen to it after signing in.

You can also turn on skipping notifications about calls in which nobody said anything.

Turning off: turning off a channel in the settings takes effect immediately. Turning off all channels does not affect messages necessary to perform the Agreement, for example an invoice, information that your minutes have run out or about a change to the Terms.

Legal basis: Art. 6(1)(b) GDPR (performance of the Agreement) and, with respect to the channels you turn on voluntarily, Art. 6(1)(a) GDPR (your consent, which you can withdraw at any time using the switch in the settings).

10. Plan, minutes and payments

The Application is available in Plans that differ in the package of call minutes per month: Starter, Professional, Business and Enterprise (terms agreed individually). The Knowledge Base and the Google Calendar connection are available from the Professional plan.

What we process in connection with the Plan: the name of the selected Plan, the start and end dates of the billing period, the number of minutes used in the current period and the number and duration of calls. You can see these figures in the web panel and in the mobile app as the package status.

Why: to show you how many minutes are left and to settle the subscription in accordance with the Terms.

Payments: they are handled by an external payment provider (Stripe). We do not store your payment card number. We receive only information about the payment status and the active subscription, as well as the data necessary to issue an invoice.

Legal basis: Art. 6(1)(b) GDPR (performance of the Agreement) and Art. 6(1)(c) GDPR with respect to accounting records.

How long: counters and billing history until the account is deleted; accounting documents for the period specified in section 5.5.

11. Google connection: Google Calendar and Google Contacts

This section applies to you only if you connect your Google Calendar or import Google Contacts in the web panel at https://app.doganswer.com. Both features are optional and the Application works without them. You give your consent on the Google screen when connecting and you can withdraw it at any time as described in point 11.5.

Both features work only in the web panel in the browser. The mobile app does not have them (see section 12).

11.1. Google Calendar

Why: during a call, the Assistant checks when you have a free slot and saves the booked appointment in your calendar. The feature is available from the Professional plan.

What permissions we request (OAuth scopes):

What we retrieve and store: the e-mail address of your Google account, the identifier of the selected calendar, the time zone, the booking hours you have set, and the access token and refresh token. The refresh token is needed because the Assistant checks free slots during calls, including when you are not signed in. We store the refresh token in encrypted form. The access token is valid for about an hour, after which we replace it with a new one.

What we do not read: during a call we retrieve only information about which time slots are busy and which are free. We do not read the titles, descriptions, attachments or attendees of your existing events.

What we save in your calendar: a single event containing the caller’s first name and surname, the subject of the appointment and the time. This event belongs to you; you can change or delete it like any other.

To whom we transfer it: information about free hours is passed to the Assistant conducting the call (voice and conversation provider: ElevenLabs) only for the duration of that call. We store the tokens and calendar settings on our server, and requests to Google Calendar are made by our automation tool (n8n) running on that server. We do not transfer these data to anyone else.

How long: we store the tokens until you disconnect the calendar in the web panel or delete your account. After disconnection we erase them immediately. Events saved in your calendar remain, because they are yours.

11.2. Google Contacts

Why: so that in the call history you see the caller’s name instead of just the number. Instead of “unknown number 600 100 201” you see the name from your contacts.

What permission we request (OAuth scope):

What exactly we retrieve from each contact:

1. first name and surname,
2. telephone numbers,
3. e-mail address,
4. the company name (organisation) assigned to the contact.

We retrieve no more than 5,000 contacts.

What we use the company name for: solely as the name displayed in the call history when the contact has no first name or surname entered. In that case, instead of an empty field, you will see the company name. We do not use the company name for any other purpose; in particular, we do not build a company database from it or use it for marketing.

The import is one-off and takes place only at your request: you start it yourself in the Contacts tab. We use the access token once, at the time of import, and we do not store it. Nor do we store a refresh token or synchronise Google Contacts in the background. Changes you later make in Google Contacts do not reach us. Another import requires renewed consent on the Google screen.

Importing from a file instead of from Google: instead of connecting to Google, you can upload a file with contacts in CSV or vCard format. The scope of data retrieved is the same, including the company name.

How long: until the account is deleted or until your request to delete the contacts sent to [email protected].

Who is the controller here: with respect to your contacts’ data, you are the controller, and we process them on your behalf. The rules are set out in the Data Processing Terms, i.e. Appendix No. 1 to the Terms.

11.3. What we do not do with data received from Google

1. We do not sell them and we do not use or transfer them for advertising purposes.
2. We do not use them to develop, train or improve artificial intelligence or machine learning models, including generalised (non-personalised) models. The AI providers through which these data pass during a call act on our instructions and do not train models on them.
3. Humans do not read them. Exceptions: you explicitly ask us to, security requires it, a legal obligation requires it, or the data are aggregated and do not allow a specific person to be identified.
4. We do not transfer them to anyone other than entities necessary for the operation of the features described above.
5. We do not transfer them to data brokers or advertising platforms and we do not use them to assess creditworthiness.

11.4. Compliance with Google policies

Doganswer’s use of information received from Google APIs and its transfer to any other app complies with the Google API Services User Data Policy, including the Limited Use requirements.

In the original wording:

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

With respect to data from Google Workspace APIs, in the original wording:

“The use of information received from Google Workspace scopes will adhere to the Google User Data Policy, including the Limited Use requirements.”

11.5. How to revoke access

1. In the web panel: the Calendar tab, the Disconnect button. We erase the tokens immediately. Disconnecting in the web panel does not remove the Doganswer entry from your Google account; you do that as described in point 2.
2. In your Google account: https://myaccount.google.com/linkedapps, select Doganswer and click Remove access.
3. Imported contacts: write to [email protected] and we will delete them. Deleting the account deletes them together with the account.
4. All data received from Google at once: write to [email protected] from the e-mail address assigned to the account. We delete the tokens, calendar settings and imported contacts within 14 days, without deleting the account.

11.6. Legal basis

Art. 6(1)(b) GDPR, i.e. performance, at your request, of the agreement for the use of the Application. We process the data of your contacts and of persons booked for appointments as a processor, on the basis of the Data Processing Terms.

12. Mobile Application

The Doganswer Mobile Application for Android and iOS gives you an overview of what the Assistant is doing, as well as basic settings. You sign in with the same account as in the web panel.

What the mobile app contains: a dashboard with the status of the minute package and forwarding rules, a list of calls with summaries, call details with the transcript and recording player, Assistant settings (greeting message, additional information, language, voice), notification settings and the account screen.

What the mobile app does not have:

This leads to the most important point of this section: the mobile app processes less data than the web panel in the browser. The mobile app does not request access to Google Calendar or Google Contacts and does not retrieve them. Its only connection with a Google account is the optional sign-in with Google, described in point 5.1.

What permissions the app requests and why:

Contacts from your phone do not leave the device. The app reads them locally, matches them against the numbers in the call history and does not send them to our server or anywhere else. This is a separate feature from the Google Contacts import, which works only in the web panel in the browser and saves contacts to the account. You will find the switch for this feature on the Account screen.

The app does not record audio. Call recordings are made on the telephone line, on our server’s side, never on your phone. The app does not use the microphone.

What the app sends to our server: the device identifier, the notification token, the device name and model, the operating system version and the app version. We need this solely to send notifications to the right phone and to know whether you are running a version we support. We store sign-in data in the phone’s secure system storage.

What the app does not have: advertisements, tools tracking your behaviour for marketing purposes, sale of data to third parties or in-app purchases. You purchase the subscription in the web panel in the browser.

How long: we store the registered device data and the notification token until you sign out of the app or delete your account.

Installation and uninstallation: you install the app voluntarily from the store. On your phone it stores sign-in data and the notification token so that sign-in and notifications work. Uninstalling removes the app and the data it saved on the phone. It does not delete the account; you delete the account separately (section 16).

13. Recipients of personal data

The recipients of personal data will be the following external entities cooperating with the Controller:

1. providers of the servers on which the Application runs and of backups (including Supabase and Amazon Web Services);
2. the telephony and SMS service provider (Twilio Inc.) and the WhatsApp notification provider (Meta – WhatsApp Business);
3. providers of external artificial intelligence models (ElevenLabs, OpenRouter, OpenAI, Google);
4. the provider of data flow automation tools (n8n);
5. providers of online payment systems (Stripe);
6. the outgoing e-mail provider (Mailgun) and the newsletter service provider;
7. providers of phone notification services (Expo, Google – Firebase Cloud Messaging, Apple);
8. companies providing tools for analysing activity on the Website (doganswer.com) and directing direct marketing (including Google – Google Tag Manager and Google Analytics, Meta – Meta Pixel);
9. the provider of the cookie consent management tool (Usercentrics, Cookiebot);
10. a company providing accounting services.

In addition, personal data may be transferred to public or private entities if such an obligation arises from generally applicable law, a final court judgment or a final administrative decision.

Twilio Inc. processes some data as an independent controller (section 5.12). Stripe processes some payment data as a separate controller, for the purpose of fraud prevention and compliance with legal obligations.

14. Transfer of data to a third country

Some providers process data in the United States: Twilio, ElevenLabs, OpenRouter and the model providers behind it, Meta, Expo, Google, Apple, Stripe (partly) and Mailgun.

The basis for the transfer is the European Commission’s implementing decision of 10 July 2023 on the EU-US Data Privacy Framework, for the providers covered by it, and otherwise the standard contractual clauses adopted by Commission Implementing Decision (EU) 2021/914 of 4 June 2021.

You can obtain a copy of these safeguards by writing to [email protected].

15. Your rights

In connection with the processing of personal data, you have the following rights:

1. right of access – the right to information on what personal data concerning you are processed by the Controller and to obtain a copy of those data. The first copy of the data is provided free of charge; the Controller may charge a fee for further copies;
2. right to rectification – if the data processed become out of date or incomplete, or otherwise incorrect, you have the right to request their rectification;
3. right to erasure – in certain situations you may ask the Controller to erase your personal data, e.g. when the data are no longer needed by the Controller for the purposes it has informed you of; when you have effectively withdrawn your consent to the processing of data, unless the Controller is entitled to process the data on another legal basis; when the processing is unlawful; when the erasure of data is required by a legal obligation to which the Controller is subject;
4. right to data portability – where personal data are processed by the Controller on the basis of consent given or for the performance of an Agreement concluded with it, you have the right to transfer your data to another controller;
5. right to withdraw consent – where personal data are processed on the basis of your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal;
6. right to restriction of processing – if you believe that the personal data processed are inaccurate, their processing is unlawful or the Controller no longer needs certain data, you may request that for a specific, necessary period the Controller does not perform any operations on the data but only stores them;
7. right to object – you have the right to object to the processing of personal data where the basis for that processing is the Controller’s legitimate interest. If an objection is effectively raised, the Controller will stop processing the personal data for that purpose;
8. right to lodge a complaint – you have the right to lodge a complaint with the President of the Personal Data Protection Office (UODO) (ul. Stawki 2, 00-193 Warsaw, Poland, https://uodo.gov.pl) if you believe that the processing of your personal data infringes the GDPR.

Right to object (Article 21 GDPR). You may at any time object to the processing of your data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) on grounds relating to your particular situation. We will then stop processing them, unless we demonstrate compelling legitimate grounds that override your interests or grounds for the establishment, exercise or defence of legal claims. An objection to direct marketing is always effective and requires no justification.

How to exercise your rights: write to [email protected] from the e-mail address assigned to the account. We respond without undue delay and in any event within one month of receiving the request. In complex cases, this period may be extended by a further two months, of which we will notify you in advance. We do not ask for a scan of an identity document.

If you called a business that uses Doganswer and want to exercise your rights with respect to the call recording, address your request to that business. It is the controller of those data. We follow its instructions. If you write to us at [email protected], we will forward your request to that business without undue delay and help it fulfil it. We do not use your call to train AI models, we do not sell it and we do not use it in marketing.

If you are concerned about the possibility of losing control over your information, about tracking of your activities or about your privacy, please note that there are a number of tools and solutions that allow such activities to be blocked: browser extensions, browser privacy settings, as well as more advanced solutions such as VPNs or browsers that offer greater privacy by rerouting traffic. We deliberately do not name specific solutions, because they are very diverse. You can find such overviews on the Privacy Guides website: https://privacyguides.org.

16. Deletion of the account and data

You can delete your account at any time and you do not have to give a reason.

Three ways, each leading to the same result:

1. In the mobile app: the Account screen → Delete account → Send the link, then clicking the confirmation link we send to the e-mail address assigned to the account.
2. In the web panel: https://app.doganswer.com → Account → Delete account → Send the link, then clicking the confirmation link we send to the e-mail address assigned to the account.
3. By e-mail or via the website: send a message from the e-mail address assigned to the account to [email protected] or use the page https://doganswer.com/en/delete-account/.

How quickly we delete:

What we delete together with the account: account data and Assistant settings, Knowledge Base entries, imported contacts, call history together with transcripts and summaries, call recordings, the Google Calendar connection together with access tokens, registered devices and notification tokens, and the record of consents to notification channels.

What remains and why:

What deleting the account does not do:

1. it does not refund the fee for a subscription period that has already started;
2. it does not automatically revoke our application’s access in your Google account. If you want to revoke it yourself, you can do so at https://myaccount.google.com/linkedapps;
3. it does not turn off call forwarding set up with the operator of your telephone number. You change this setting yourself, with your operator.

If you want to delete only some of your data: write to [email protected]. We can delete individual recordings, imported contacts and Knowledge Base entries without deleting the account.

17. Cookies

The Controller informs you that the Application uses “cookies” installed on your terminal device. These are small text files that can be read by the Controller’s system as well as by systems belonging to other entities whose services the Controller uses (e.g. Meta, Google).

The Controller uses cookies for the following purposes:

1. ensuring the proper functioning of the Application – cookies enable the Application to run smoothly, its features to be used and convenient navigation between individual subpages;
2. improving the convenience of using the Application – cookies make it possible to detect errors on some subpages and to continuously improve them;
3. creating statistics – cookies are used to analyse how users use the Application;
4. conducting marketing activities – cookies allow the Controller to show users advertisements tailored to their preferences.

The Controller may place both persistent and temporary (session) cookies on your device. Session cookies are usually deleted when the browser is closed, whereas closing the browser does not delete persistent cookies.

Information about the cookies used by the Controller is displayed in the cookie consent panel available on the Website. Analytics and marketing scripts on the Website are loaded by Google Tag Manager and run only after you give your consent in that panel. The web panel at https://app.doganswer.com uses only strictly necessary cookies, needed to keep you signed in. Depending on your decision, you can enable or disable cookies of individual categories (except strictly necessary cookies) and change these settings at any time.

List of cookies used on the Website (based on the CMP scan, 7 cookies):

The data collected by means of cookies do not allow the Controller to identify you.

The mobile app does not use cookies or advertising identifiers.

Most commonly used browsers allow you to check whether cookies have been installed on your terminal device, as well as to delete installed cookies and block their future installation by the Application. However, disabling or restricting cookies may cause quite serious difficulties in using the Application, e.g. the need to sign in on every subpage, longer loading times of the Application, or restrictions on the use of some features.

18. Final provisions

In matters not regulated by the Policy, generally applicable personal data protection laws apply.

We will notify you in advance of any material change to the Policy at the e-mail address assigned to the account and in the Application.

The Policy is effective from 22 June 2026. Last updated: 28 September 2026.