Privacy Policy | CallDear

1. Who we are

CallDear is run by Nova Digital Systems LLP, a limited liability partnership registered in England and Wales under number OC460186. Registered office: Stoney Works, 8 Stoney Lane, London SE19 3BD, United Kingdom. In this policy, “we” and “us” mean Nova Digital Systems LLP.

We are the controller of the personal information described here: we decide why and how it is used, and we are responsible for it under UK data protection law (the UK GDPR and the Data Protection Act 2018). This policy covers the CallDear calls, the family web app and this website.

We have not appointed a data protection officer. For anything about your information, write to privacy@calldear.com, and the person responsible for privacy at CallDear will reply.

CallDear is an AI voice assistant that calls an older person at the request of their family, talks with them, and gives the family a short summary. Two kinds of people are involved: the person who receives the calls, and the family members who set them up.

2. What we collect and where it comes from

About the person who receives the calls

Most of this comes from the family member who sets up the calls: they give us the person’s name, phone number and the other details below. The rest comes from the person themselves, in what they say during calls, or is produced by our service from those calls.

Identity and contact: name, how they like to be addressed, phone number, relationship to the family member, time zone and convenient call times.
What the family tells us: for example age and a photo (both optional), interests, topics to ask about or avoid, and questions the family would like the assistant to ask next time.
Consent and opt-out records: the audio and transcript of the recorded part of the consent call, the family member’s confirmation, the time, the number and the version of the wording; and records of any request to stop the calls.
Conversations: transcripts of calls, technical logs of each call (which can include short fragments of what was said), and call details (time, duration, whether the call was answered).
What we derive from conversations: short summaries for the family; notes the assistant keeps so it can remember earlier conversations (for example, “her granddaughter is visiting on Sunday”); topics discussed; and alerts when something worrying was said.

Conversations may include sensitive information, such as health, mood or family matters. We use it only to provide the service described here. CallDear is not a healthcare provider, and a summary is not a medical record. How we handle health information is also explained in our Consumer Health Data Privacy Policy.

About family members

Name, email address, phone number, relationship to the person called, which family members receive alerts and how (phone call, text message or email), sign-in links and activity in the family app, and messages you send us. You give us this yourself, or the family member who invites you gives us your name and contact details.

About visitors to this website

This website uses no cookies, analytics, advertising or tracking tools, runs no scripts, and loads nothing from other companies. Our hosting provider keeps standard technical logs of requests (such as IP address, time and the page requested) for security and reliability.

3. Why we use it, and our legal reasons

UK law requires a legal reason (a “lawful basis”) for every use of personal information. Below is each use and its reason. Health and other sensitive information needs an extra condition, which we also name.

Running the family account, and sending summaries and alerts to family members: Our contract with the family (Article 6(1)(b) UK GDPR).
Keeping the details the family gives us about the person, and placing the consent call: Our legitimate interests, and the family’s, in setting up the calls and asking the person whether they would like them (Article 6(1)(f)). Until the person agrees, these details are used only to place the consent call and to show the family what they entered.
Calling the person, talking with them, remembering earlier conversations, and telling the family how they are: The person’s consent, given in their own words in the consent call (Article 6(1)(a)). For health and other sensitive information they share, their explicit consent (Article 9(2)(a)).
Urgent alerts when someone may be in danger: The same consent: the consent question tells the person that worrying things are passed on to the family. Where someone’s life or safety may be at risk, also the recognised legitimate interest in safeguarding a vulnerable person (Article 6(1)(ea)), and, if the person cannot give consent, protecting their vital interests (Article 9(2)(c)).
Keeping proof of consent and of opt-outs: Our legitimate interests in being able to show that calls were made with consent and in keeping to every opt-out (Article 6(1)(f)). For any sensitive information in these records, establishing, exercising or defending legal claims (Article 9(2)(f)).
Checking the quality and safety of calls: Our legitimate interests in a safe service that works (Article 6(1)(f)); for sensitive information in the conversations, the person’s explicit consent (Article 9(2)(a)).
Keeping the service and this website secure, including technical logs: Our legitimate interests in protecting the service and the people who use it (Article 6(1)(f)).
Meeting our legal obligations and answering lawful requests: Legal obligation (Article 6(1)(c)); for telephone industry requests to trace where a call came from, our legitimate interests in keeping our calls trusted (Article 6(1)(f)).

In practice, this means we use information:

To place calls on the schedule the family chose, and to let the assistant talk naturally and remember earlier conversations.
To give the family summaries and, when something worrying comes up, alerts.
To keep proof of consent and of opt-outs, and to honor them.
To keep the service working and secure: people who run the service may review recent transcripts when that is needed to fix a problem or check the quality of calls.
To check the quality and safety of the assistant’s replies automatically: every night, a sample of the previous day’s conversation turns is sent to the language-model provider described below, and the problems it finds are reported to the people who run the service.
To comply with the law and respond to lawful requests.

The person who receives the calls can withdraw their consent at any time, by saying so in a call or by email (see the Calling & Consent Policy). That stops the calls and any new use of their information based on consent from then on; it does not make earlier use unlawful. What we keep after that is described in section 6.

If the person asks the assistant to keep something between them, it is kept out of what the family sees, unless it suggests a risk to their life or safety.

We do not use personal information for advertising, we do not sell it, and we do not share it for cross-context behavioral advertising. We do not train AI models on conversations ourselves; what our providers may do is described in the next section.

5. Sending information abroad

We are based in the United Kingdom. Our server is in Germany, and several of the providers above are in the United States. UK law allows this only when the information stays protected:

Germany and the rest of the European Economic Area: the UK has recognised their data protection laws as adequate (UK adequacy regulations).
United States: for a provider certified under the UK Extension to the EU-US Data Privacy Framework, the UK’s adequacy regulations for certified companies; for other providers, the UK International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses, included in the provider’s data processing terms.
Other countries: only when OpenRouter passes a request to a backup model provider outside the United States and the European Economic Area, as described in section 4. That provider does not keep the request, and the transfer is covered by the UK International Data Transfer Agreement or the UK Addendum in OpenRouter’s data processing terms.

You can ask us for a copy of these safeguards at privacy@calldear.com.

6. How long we keep information

We keep information only as long as we need it. Information we delete from our systems stays in our backup copies for about 30 more days and is then deleted automatically. Where this applies, the period below is marked “+ about 30 days in backup copies”.

Consent records: The audio and transcript of the recorded part of the consent call (the notice, the question and the answer), the family member’s confirmation, the number the call came from, the time and the wording version, and the record of any withdrawal of consent. We keep them even if the person’s other information is deleted, for 7 years after the last event connected with them: the consent call, the last call made with that consent, its withdrawal, or the deletion of the person’s information. While the person is still registered with us, we keep their most recent consent record (a yes, a no or a request to stop) until a newer one replaces it or their information is deleted, because it is what tells us whether we may call them. If there is ever a dispute, we may need to show that the calls were made with consent, and in England a claim can be brought up to six years later. + about 30 days in backup copies
A “no” in the consent call: When the family member records the person’s answer as a no, to the calls or to being recorded, the audio and transcript of that call are deleted at our next daily deletion run, normally within 24 hours and in any case within 30 days, and we keep only a short record of the answer, without their voice or words. That record says what the answer was, when it was given, which wording was used, which number was called and which family member recorded the answer; we keep it as long as consent records. If the family member does not record an answer, the recording is kept like other consent records. + about 30 days in backup copies
Word-for-word call transcripts: In our database, 90 days, then deleted automatically. + about 30 days in backup copies
Technical call logs: A step-by-step log of each call (for example, which safety steps the assistant took), which can include short fragments of what was said. We delete the whole log automatically after 30 days, or together with the person’s other information if that is deleted first. + about 30 days in backup copies
Call measurements: Timings and similar measurements of each reply in a call (for example, how long the assistant took to answer and how sure speech recognition was), with the time of the call and the person’s phone number but without what was said. 90 days, or until the person’s information is deleted, if that comes first. + about 30 days in backup copies
Audio of regular calls: Not stored.
Temporary copy of a consent recording: Kept on our server only until the recording is safely stored, and in any case deleted within 25 hours.
Summaries, memory notes, alerts, call history, the person’s profile and family contact details: As long as the family account is active, or until you ask us to delete them. When the family account is closed, or the person’s information is deleted at their or their family’s request, we delete this within 30 days. + about 30 days in backup copies
Record of a deletion: When we delete a person’s information, we keep a note that we did: their phone number and the date of the deletion, so that we can show the request was carried out. Kept for 7 years after the deletion. + about 30 days in backup copies
Backup copies: Copies of our database and technical call logs, kept on our server and, encrypted, with Cloudflare. Each copy is deleted automatically about 30 days after it is made, so anything we delete from our systems is gone from the copies about 30 days later.
Emails you send us: As long as we need them to answer you and to show how we handled your request.
Website request logs: Kept by our hosting provider for a short time, under its own terms.

7. Your rights

You have the rights below. The person who receives the calls can use them, and so can the family account holder for the account’s information, or someone the person has asked to act for them.

See it: ask for a copy of the information we hold about you or your relative, and how we use it.
Correct it: ask us to fix anything that is wrong or incomplete.
Delete it: ask us to delete a person’s information or the whole family account. Within 30 days we delete the person’s profile, memory notes, summaries, transcripts, call history, call measurements and technical call logs, so the assistant no longer remembers anything about them; backup copies follow about 30 days later. We keep only the consent records and the record of the deletion described in section 6, because we may need them to show that the calls were made with consent and that the deletion was done. The assistant cannot call the person again unless they give consent in a new consent call. We also ask the providers that may still hold a copy, such as ElevenLabs’ history of generated speech, to delete it.
Limit how we use it: ask us to keep the information but stop using it, for example while we check whether it is correct.
Object: object to any use based on our legitimate interests (section 3). We will stop, unless we have compelling reasons that outweigh yours or need the information for a legal claim.
Take it with you: ask for the information you gave us, in a common computer format, or ask us to send it to someone else.
Withdraw consent: stop the calls at any time, as described in the Calling & Consent Policy.

See and correct it yourself

In the family app, family members can see the person’s profile, call schedule, topics, summaries, alerts and consent status, and change the profile, the schedule, the topics and who gets alerts. For anything else, or if you are the person who receives the calls, email us.

How to ask, and how quickly we answer

Write to privacy@calldear.com. We may need to confirm that a request really comes from you before acting on it, for example by checking with the email address or phone number on the account. We answer within one month. If a request is complex, or you send several, we may need up to two more months; we will tell you so, and why, within the first month. Using these rights is free.

If we cannot do what you ask, we will tell you why, and that you can complain to us, complain to the Information Commission, or ask a court to decide. We will not treat anyone differently for using these rights.

8. Complaints

If you are unhappy with how we handle your information, please tell us: write to privacy@calldear.com. An email is enough, and no form is needed. We confirm that we have received your complaint within 30 days, look into it, and tell you the outcome without undue delay.

You can also complain to the Information Commission, the UK’s data protection regulator (formerly the Information Commissioner’s Office), at ico.org.uk.

9. Do you have to give us information?

No law requires anyone to give us information. To open a family account, you need to give your name and a way to reach you; without them we cannot provide the service. To set up calls, we need the person’s name and phone number; the other details about them are optional.

The person who receives the calls does not have to tell the assistant anything, and does not have to agree to the calls. Without their own yes in the consent call, there are no calls.

10. Automated decisions

Some things happen automatically: the assistant decides what to say, writes summaries and memory notes, notices when something said sounds worrying and sends an alert, and stops the calls when the person asks it to.

We do not make decisions about anyone based solely on automated processing that have legal or similarly significant effects on them. Whether a person agreed to the calls is decided by a person — the family member who heard the answer — not by a machine. If you think something the assistant did automatically was wrong, tell us, and a person will look at it.

11. Security

Connections to our websites, and from our server to our speech and language providers, are encrypted in transit. The calls themselves travel over the public telephone network, like any phone call. Our databases are not reachable from the internet, off-site backups are encrypted, and access to personal information is limited to the people who run the service. No system is perfectly secure; if a breach affects your information, we will tell you as the law requires.

12. Children

CallDear is not intended for children. We do not knowingly collect information from children under 13. Family accounts are for adults aged 18 or older, and the people who receive calls are adults. If you believe a child has given us information, contact us and we will delete it.

13. If you live in the United States

Health information. Our Consumer Health Data Privacy Policy explains how we handle health information under Washington’s My Health My Data Act and similar state laws.

Do Not Track. Some browsers send a “Do Not Track” signal. This website does not track visitors over time or across other sites, and does not allow other companies to collect information about you here, so the signal changes nothing.

California. This policy is intended to meet the California Online Privacy Protection Act. We do not share personal information with third parties for their own direct marketing.

Other state laws. We do not sell personal information or use it for targeted advertising. If we turn down a request you make under a US state privacy law, you can appeal by replying to our answer. We decide an appeal within 45 days and explain our decision; if we turn it down, you can contact your state attorney general.

14. Changes to this policy

We post every change on this page with a new effective date. If a change is material, we tell family account holders by email before it takes effect. If a change would affect what a person agreed to in the consent call, we ask them again before relying on it.

15. Contact

Nova Digital Systems LLP, registered office: Stoney Works, 8 Stoney Lane, London SE19 3BD, United Kingdom.
Privacy questions, requests and complaints: privacy@calldear.com.
Anything else: support@calldear.com.

In short