1. Parties and roles
- The business that uses Linesteward is the controller ("you").
- Adria Technologies Limited, trading as Linesteward, a company registered in England and Wales, company number 17543235, registered office 66 Paul Street, London, EC2A 4NA, is the processor ("we").
This agreement is part of our Terms of service. It applies to personal data we process for you when the service handles your calls. Where it differs from the terms, this agreement wins on data protection.
2. Details of the processing
| Subject matter | Answering your business's phone calls with an AI receptionist, and the dashboard that shows the results. |
|---|---|
| Duration | While you use the service, and until the data is deleted as in section 11. |
| Nature | Receiving call audio as a live stream; turning speech into text and text into speech; generating replies with an AI language model; storing transcripts, summaries, messages and bookings; storing the text of documents you upload for the receptionist to answer from (the file itself is kept only while it is read, then deleted); sending text messages; passing calls to a number you choose; sending bookings to a booking system you connect. |
| Purpose | To answer calls for you, take messages and bookings, answer questions and pass urgent calls to you. |
| Types of personal data | Callers' voices (streamed live, not stored by us); call transcripts and summaries; phone numbers; names; addresses and call-back times given in messages; booking details and notes; any personal data in the text of documents you upload. Callers may also give special category data, such as health details. |
| Data subjects | People who call your business (your customers and others). Your staff, where they are named in calls or are the person calls are passed to. |
Your own account details, the details we send to our phone network provider for a new number, and what you type into our chat helper are not covered by this agreement: we are their controller, as our Privacy notice explains.
3. Instructions
- We process the data only on your documented instructions. These terms, and the settings you choose in the service (for example how long data is kept, the alert number and the booking system), are your instructions. This includes transfers abroad (section 10).
- If the law makes us process data in another way, we will tell you first, unless the law forbids that.
- We will tell you at once if we think an instruction breaks data protection law.
- We do not use your callers' data for our own purposes, and we do not use it to train AI models. Our providers may not use it to train their models.
- The receptionist says it is an AI at the start of every call, as the EU AI Act (Article 50) asks.
4. Confidentiality
Everyone we allow to process the data is bound by a duty of confidentiality.
5. Security
We take appropriate technical and organisational measures (Article 32). Today these are:
- data is sent over encrypted connections (TLS);
- the server checks that you belong to a business (a database check) before every read or write of its data;
- keys and links for connected booking systems are stored encrypted (pgcrypto), with a key that only our server holds;
- access to production systems is limited to the people who run the service;
- call audio is not stored by us;
- a nightly job deletes transcripts, summaries, caller numbers, messages and past bookings once your retention times pass.
- API access is yours to control: only an owner or admin of your account can make an API key; a key reaches only your account's data, within the scopes you choose; we keep only a keyed fingerprint of it (never the key); you can revoke it at any time; and each request made with a key is logged (the time, method, endpoint and status, never the data) for 90 days. When a request carries an Idempotency-Key, its answer (which can hold a caller's or customer's personal data) is kept for 24 hours so a retry gets the same answer, then deleted.
Retention
Your settings set how long data is kept. The defaults are:
| Data | Default | You can set |
|---|---|---|
| Call audio | Not stored | — |
| Call transcripts, summaries and caller numbers | 90 days | 7 to 730 days |
| Messages, and bookings once their time has passed | 365 days | 30 to 2190 days |
| Text of documents you upload | Until you delete the document, or the business (the uploaded file is kept only while it is read, then deleted) | Delete any document at any time |
A job runs every night and deletes data once its time has passed. Call audio is not stored: it is streamed live and is not kept by us.
6. Sub-processors
- You give us general permission to use sub-processors of the types below. We give you their names on request at support@linesteward.com.
- We will tell you at least 30 days before we add or replace one. You may object for a reasonable data protection reason. If we cannot solve it, you may end the service.
- Each sub-processor is bound by data protection terms that protect the data as well as this agreement does. We stay responsible to you for them.
| Type of provider | Where | Transfer safeguard |
|---|---|---|
| Cloud hosting and database | EU (Germany); providers with US parent companies | Data stays in the EU, which the UK treats as adequate. For any access from the US: UK Addendum to the EU SCCs or UK IDTA, or the UK–US Data Bridge where the provider is certified |
| Phone network | US | UK Addendum to the EU SCCs or UK IDTA, or the UK–US Data Bridge where the provider is certified |
| Speech to text and text to speech | US | UK Addendum to the EU SCCs or UK IDTA, or the UK–US Data Bridge where the provider is certified |
| AI language model | US | UK Addendum to the EU SCCs or UK IDTA, or the UK–US Data Bridge where the provider is certified |
| Payments | US | UK Addendum to the EU SCCs or UK IDTA, or the UK–US Data Bridge where the provider is certified |
| Email delivery | US | UK Addendum to the EU SCCs or UK IDTA, or the UK–US Data Bridge where the provider is certified |
7. Help with people's rights
- Callers may ask you to see, correct or delete their data. We help you answer.
- You can see and read each call, message and booking in your dashboard.
- On your request we can erase one caller's data for your business: their call transcripts, summaries and number on the call log, and their messages and bookings.
- If a caller contacts us directly, we pass the request to you and do not answer it ourselves, unless you ask us to.
8. Data breaches
We tell you without undue delay after we become aware of a personal data breach that affects your data, and we aim to do so within 48 hours. We give you the information you need to report it to the ICO and to tell callers, and we help you limit the harm.
9. DPIAs and the ICO
We help you with data protection impact assessments and any prior consultation with the ICO, as far as they concern our service.
10. International transfers
- Our database is in the EU (Frankfurt, Germany), which the UK treats as adequate.
- Some sub-processors are in the US, and our EU hosting providers have US parent companies (see section 6). For them we rely on the UK Addendum to the EU Standard Contractual Clauses (SCCs) or the UK International Data Transfer Agreement (IDTA), and the UK–US Data Bridge where the provider is certified.
11. Deletion at the end
When the service ends, we delete your callers' personal data within 30 days, unless the law requires us to keep it. Before then you can read and copy it from your dashboard, or ask us to return it to you. Copies in backups are deleted as the backups expire.
12. Information and audits
We give you the information you reasonably need to show that this agreement is followed. We first answer a written questionnaire. If that is not enough, you may audit us, with reasonable notice, at your cost, and at most once a year unless there has been a breach.
13. Your duties as controller
- You have a lawful basis for the processing, and a condition for any special category data (for example health details at a clinic).
- You tell your callers how their data is used, in your own privacy notice, including that calls are transcribed. The receptionist tells callers at the start that it is an AI, and tells them the call is transcribed if they ask.
- You set retention times that suit your business, and you do not use the service for marketing calls or texts.
- If you give an API key to a developer or another company, they act for you, under your own contract with them (Article 28). You decide who has a key, and you look after the data they take out of the service. Our deletion of old data does not reach those copies.
14. General
The liability terms in section 15 of the Terms of service apply to this agreement. This agreement is governed by the law of England and Wales. Questions: support@linesteward.com.