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Effective Date: January 1, 2026

Privacy Policy

This Privacy Policy details how Elamora processes personal information, telephony streams, audio recordings, and vector embeddings in compliance with global data protection laws including GDPR and CCPA/CPRA.

Core Data Protection Commitments

Tenant-Level Data Isolation

All Customer Data, embeddings, and conversation transcripts are strictly isolated by workspace ID with database row-level enforcement.

No Foundation Model Training

We do not use customer conversational audio, transcripts, or uploaded RAG documents to train or tune public AI foundation models.

Zero Data Monetization

We never sell, rent, or trade customer data or end-user personal details to advertisers or third-party data brokers.

Policy Sections
  • 1. Scope & Data Roles
  • 2. Information We Collect
  • 3. Legal Bases for Processing
  • 4. AI & Model Training Disclosures
  • 5. Telephony, Audio & Call Consent
  • 6. Sub-processors & Third Parties
  • 7. International Data Transfers
  • 8. Security, Isolation & Retention
  • 9. Your Rights (GDPR & CCPA/CPRA)
  • 10. Children's Privacy
  • 11. Contact & Inquiries

1. Scope & Data Roles (Controller vs. Processor)

This Privacy Policy applies to the software platform, websites, APIs, and AI voice services operated by Elamora (“Elamora”, “we”, “us”, or “our”). Under data privacy laws such as the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA/CPRA), our role depends on the context of the data being processed:

Elamora as a Data Controller:We act as a Data Controller with respect to account administrative details, billing contacts, direct website inquiries, and telemetry metadata gathered directly from our subscribed business users.
Elamora as a Data Processor / Service Provider:With respect to conversational recordings, customer contacts imported into the CRM, call transcripts, and documents ingested into the RAG knowledgebase (“Customer Data”), the subscribing customer operates as the Data Controller. Elamora processes this data strictly as a Data Processor on behalf of the customer, in accordance with the customer's instructions and our Data Processing Addendum (DPA).

2. Information We Collect

Depending on how you interact with the Elamora platform, we process the following categories of information:

  • Account & Workspace Data: Name, work email address, company name, workspace configuration, billing contact, and encrypted authentication credentials.
  • CRM & Contact Records: Lead names, phone numbers, email addresses, custom CRM properties, and appointment booking details entered or synced by workspace users.
  • Voice Audio & Transcripts: Audio streams transmitted during inbound and outbound phone calls, synthesized text-to-speech audio files, and automated speech-to-text transcripts generated during AI interactions.
  • Knowledgebase Materials (RAG): Textual documents (PDF, DOCX, TXT) and website URLs ingested by your administrators to generate vector embeddings that ground agent responses.
  • Telephony Telemetry: Session Initiation Protocol (SIP) response codes, call duration, latency benchmarks, packet loss telemetry, and carrier routing codes.
  • Technical & Log Data: IP addresses, browser user-agent strings, access timestamps, and API call logs utilized for security monitoring and audit trails.

3. Legal Bases for Processing (GDPR)

If you reside in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data under the following lawful bases established by Article 6 of the GDPR:

  • Performance of a Contract (Art. 6(1)(b)): To provision your tenant instance, route voice conversations, execute AI dialogue flows, reserve calendar slots, and provide customer support.
  • Legitimate Interests (Art. 6(1)(f)): To secure our infrastructure against malicious attacks, investigate fraudulent telephony traffic, prevent bot abuse, and optimize platform latency.
  • Legal & Regulatory Compliance (Art. 6(1)(c)): To satisfy telecommunications regulations (e.g., STIR/SHAKEN identity validation, FCC robocall mitigation rules), tax records, and lawful government requests.
  • Consent (Art. 6(1)(a)): Where explicitly solicited for optional marketing communications or non-essential cookies.

4. Artificial Intelligence & Model Training Disclosures

Elamora integrates advanced large language models (LLMs), real-time speech processing, and retrieval-augmented generation (RAG) to deliver autonomous voice and chat capabilities. We adhere to clear data governance principles:

Strict Enterprise API Protections

Customer conversations, voice audio clips, transcripts, and uploaded RAG knowledgebase contents are processed exclusively through commercial enterprise API pipelines. We do not use Customer Data to train, fine-tune, or improve public foundation models (including OpenAI models), nor do our API providers retain customer prompt data for model training purposes.

Vector embeddings created from your knowledgebase documents are stored within isolated vector partitions in our managed database and are accessed strictly within your tenant's authenticated scope during search queries.

5. Telephony, Voice Recordings & Call Consent

Because Elamora facilitates public switched telephone network (PSTN) calls, specific telecommunications legal frameworks apply:

  • Recording Consent Responsibility: Numerous jurisdictions enforce all-party or two-party consent laws governing the recording of telephone conversations (e.g., California Penal Code § 632, German Criminal Code § 201). As the data controller initiating or receiving calls, the Customer is solely responsible for ensuring that all legally mandated recording disclosures are audibly communicated to call participants.
  • Automated Disclosures: Elamora provides configurable greeting announcements and audible beeps within agent settings to assist customers in fulfilling call recording disclosure requirements.
  • Carrier Telephony Trunks: Telephony traffic is transported via licensed telecommunications carrier networks (including Telnyx LLC) in compliance with STIR/SHAKEN caller identification standards.

6. Sub-processors & Third-Party Service Providers

Elamora engages vetted third-party vendors (“Sub-processors”) to deliver critical components of our architecture. Each sub-processor is subject to contractual obligations guaranteeing confidentiality and data protection standards no less stringent than those outlined in this policy:

Telnyx LLCTelecommunications Carrier

PSTN voice telephony, SIP trunking, SMS delivery, and WhatsApp Business API routing.

OpenAI, LLCAI & Speech Provider

Realtime voice API inference, speech-to-text transcription, and embedding generation via enterprise zero-data-retention APIs.

PostgreSQL & Vector InfrastructureCloud Database Hosting

Encrypted relational database storage and pgvector indexing with tenant-isolated schema controls.

Stripe, Inc.Payment Gateway

PCI-DSS Level 1 compliant subscription processing and invoice management. Elamora does not store raw credit card numbers.

7. International Data Transfers

Elamora operates servers and cloud infrastructure primarily in the United States and the European Union. When data is transferred across international borders, we ensure adequate data transfer mechanisms are implemented in compliance with GDPR Chapter V:

  • Execution of Standard Contractual Clauses (SCCs) approved by the European Commission.
  • Implementation of the UK International Data Transfer Addendum (IDTA).
  • Supplemental technical safeguards, including end-to-end transport encryption (TLS 1.3) and AES-256 data at rest encryption.

8. Security, Isolation & Retention

We implement robust technical and organizational measures (TOMs) designed to prevent accidental loss, unauthorized access, alteration, or disclosure of Customer Data:

  • Multi-Tenant Isolation: Relational records and pgvector embeddings are logically partitioned by tenant ID to guarantee cross-tenant isolation.
  • Encryption: Data in transit is encrypted using TLS 1.3; data at rest is encrypted using AES-256 standards.
  • Retention Periods: Workspace operational data is maintained for the duration of the customer's active subscription. Workspace administrators may configure automated retention rules to purge call transcripts and audio recordings on customizable schedules.
  • Post-Termination Purge: Following account cancellation or termination, workspace data is preserved for a 30-day grace window before being permanently and irreversibly purged from our active databases.

9. Privacy Rights (GDPR & CCPA/CPRA)

Depending on your geographic location, you possess statutory rights regarding your personal information:

European & UK Rights (GDPR):

  • Right of Access: Obtain confirmation whether your personal data is processed and receive a copy.
  • Right to Rectification: Request correction of inaccurate or incomplete personal records.
  • Right to Erasure (“Right to be Forgotten”): Request deletion of personal information where statutory grounds are met.
  • Right to Restriction & Objection: Restrict processing or object to processing based on legitimate interests.
  • Right to Data Portability: Receive personal information in a structured, commonly used, machine-readable format (e.g., CSV, JSON).
  • Right to Lodge a Complaint: File a grievance with your national Data Protection Supervisory Authority.

California Consumer Rights (CCPA/CPRA):

  • Right to Know & Access: Learn categories and specific pieces of personal information collected over the preceding 12 months.
  • Right to Delete: Request deletion of personal information collected from you.
  • Right to Correct: Request correction of inaccurate personal details.
  • No Sale or Sharing: Elamora does not sell personal information, nor do we share personal information for cross-context behavioral advertising.
  • Non-Discrimination: We will never discriminate against you for exercising your CCPA privacy rights.

To exercise any of these rights, contact our privacy compliance team at privacy@elamora.cloud. If you are an end-user customer of an organization using Elamora, please direct your request directly to that organization (the Data Controller).

10. Children's Privacy

Elamora is an enterprise business-to-business (B2B) communications platform and is not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 16 years of age. If we discover that a minor has provided us with personal information, we will take immediate steps to delete such data from our records.

11. Contact & Inquiries

If you have questions, concerns, or requests regarding this Privacy Policy or our data handling practices, please contact our Data Protection Officer and compliance team:

Privacy Compliance Office

Direct all DPA execution, GDPR requests, and compliance questions to our team.

privacy@elamora.cloud
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