Privacy Policy

Last Updated: 2025.12.20

New Limits Coaching LLP, brand name friendlyAI.studio, together with its affiliates (“friendlyAI”, “we”, “our”, or “us”), provides a business-to-business voice-based artificial intelligence platform for automated customer interactions and related software services (collectively, the “Platform” or “Services”).

This Privacy Policy (“Policy”) describes how we collect, use, disclose, and protect personal information in connection with our website, business operations, and the Services.

If you do not agree with this Policy, please do not use the Services.

1. Scope of This Policy

For purposes of this Policy:

• Customer means an organization that has entered into an agreement with friendlyAI to use the Services.

• Authorized User means an individual authorized by a Customer to access the Services on its behalf.

• End User means an individual who interacts with a Customer’s voice agent through the Services (e.g., a caller).

This Policy applies to:

• Website visitors;

• Prospective and existing Customers;

• Authorized Users.

This Policy does not apply to End Users.

End User personal information is processed by friendlyAI solely on behalf of and under the instructions of the relevant Customer, pursuant to applicable agreements.

End Users should consult the privacy notice of the organization they interacted with.

2. Roles Under Data Protection Laws

Under applicable data protection laws:

• Customers act as data controllers with respect to End User personal information.

• friendlyAI acts as a data processor when processing End User data on behalf of Customers.

Customers are solely responsible for:

• Determining the purposes and legal bases for processing;

• Providing required notices to End Users;

• Obtaining all legally required consents, including consent for call recording.

3. Personal Information We Collect

A. Information You Provide to Us (Controller Role)

We may collect information directly from Customers and Authorized Users, including:

• Name, business email address, phone number;

• Company name, job title, and role;

• Account credentials;

• Billing and payment information;

• Communications with us (including support inquiries).

B. Information Processed on Behalf of Customers (Processor Role)

In providing the Services, we may process the following End User data on behalf of Customers:

• Voice call audio recordings;

• Automatically generated call transcripts;

• Call metadata (such as date, time, duration, and routing information).

We process such information only in accordance with Customer instructions and applicable agreements.

4. Call Recording and Transcripts

Calls handled through the Services may be recorded, and transcripts may be generated automatically using speech-to-text technologies.

• Audio recordings and transcripts are retained for up to 30 days, unless otherwise instructed by the Customer or required by law.

• After the applicable retention period, such data is deleted or anonymized.

• Customers may access and export transcripts during the retention period.

Customers are solely responsible for ensuring that End Users are provided with appropriate notice and that all legally required consents for call recording and processing are obtained.

5. Use of Artificial Intelligence and Third-Party Providers

The Services utilize artificial intelligence technologies, including large language models (“LLMs”), to process voice interactions and generate responses.

We may engage third-party providers, including:

• OpenAI (ChatGPT);

• Vapi;

• Bland AI;

• Cloud infrastructure and voice service providers.

These providers process data solely to provide the Services and in accordance with contractual data protection obligations.

Unless expressly agreed otherwise, friendlyAI does not use End User voice data to train or improve third-party foundation models.

6. How We Use Personal Information

We use personal information to:

• Provide, operate, and maintain the Services;

• Manage customer accounts and billing;

• Respond to inquiries and provide support;

• Monitor performance, reliability, and security;

• Comply with legal and regulatory obligations;

• Improve the Services using aggregated or de-identified information.

7. Data Retention

• Voice recordings and transcripts: retained for up to 30 days;

• Customer account and business records: retained for the duration of the contractual relationship and as required by law;

• Aggregated or de-identified information: may be retained indefinitely.

8. Disclosure of Personal Information

We may disclose personal information to:

• Service providers and subprocessors that support the operation of the Services;

• Professional advisors (legal, accounting, security);

• Authorities where required by law.

All subprocessors are subject to contractual confidentiality and data protection obligations.

9. International Data Transfers

Personal information may be processed in Canada, the United States, and other jurisdictions where our service providers operate.

We implement appropriate safeguards to protect personal information in accordance with applicable data protection laws.

10. Security

We implement administrative, technical, and organizational measures designed to protect personal information, including access controls, encryption where appropriate, and monitoring.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Individual Rights

Authorized Users and business contacts may request access, correction, or deletion of their personal information, subject to applicable law.

End Users should direct any privacy requests to the relevant Customer. friendlyAI will provide reasonable assistance to Customers in responding to such requests where required by law.

12. Changes to This Policy

We may update this Policy from time to time. Updates will be posted with a revised “Last Updated” date.

13. Contact Information

For questions or concerns regarding this Policy, please contact:

Email: legal@friendlyai.studio

Address: New Limits Coaching LLP 1103-11871 Horseshoe Way, Richmond, BC, V7A 5H5, Canada