Dusklin

Processing terms

Version dated 2026-09-23; every dated version is kept. These terms are part of your agreement with OdileUSA L.L.C. (Dusklin) from the day you start a plan, and they are written to do what Article 28 of the UK GDPR and the EU GDPR asks of a processor. Ask and we send a signed copy.

Who is who

You, the business whose line we answer, are the controller of your callers' personal data. OdileUSA L.L.C., trading as Dusklin, is your processor. For your own account, billing and correspondence with us, we are the controller, as the privacy policy says.

What we process, and why

Subject matter: answering your telephone line and delivering what callers ask for to you. Data: callers' phone numbers where the network shows them, the audio and transcript of each call, and whatever a caller says: their name, callback number, address, what they need and how urgent it is, an appointment, and sometimes other people they mention. If callers may tell you about their health (a clinic, a practice), that is special-category data: you instruct us to take it only if your own lawful basis is in place, and you say so in your rules. People: your callers, usually your customers and prospects. Duration: the life of your subscription plus the deletion periods below.

Your instructions

Your documented instructions are these terms, your account settings, the rules you send us, and the transfer to the United States described below. We process callers' data only on them, unless a law we are subject to requires otherwise, in which case we tell you before we act where the law allows. If we think an instruction breaks data-protection law, we tell you at once and wait.

Our promises as your processor

  1. Confidentiality. Everyone who can see your callers' data is bound in writing to keep it confidential.
  2. Security. We take the measures Article 32 asks for, matched to the risk: the API links we control run over TLS; our storage at Cloudflare is encrypted at rest; access is limited to the people and services that need it and authenticated with per-service secrets that are rotated when a person leaves or a key is exposed; call records expire on schedule; we test our own systems and keep restore copies of configuration. Email to you travels encrypted when your mail server offers TLS, and the telephone network itself is not encrypted end to end; we do not promise what the network cannot give.
  3. Sub-processors. You give general written authorisation for those listed below. We add or replace one only after emailing you at least 30 days ahead; you may object in writing, and if we cannot resolve it you may cancel with a refund of any unused month. We bind every sub-processor by contract to protections equivalent to these terms and stay responsible to you for what they do.
  4. Helping with rights. We help you answer your callers' requests about their data (access, correction, deletion, restriction, portability, objection) within the time the law gives you; callers who write to us are pointed to you.
  5. Helping with your duties. With the information we hold, we help you meet your security, breach-notification, impact-assessment and prior-consultation duties under Articles 32 to 36.
  6. End of service. When your subscription ends you choose: we return your callers' data in a usable form, or we delete it. Either way we delete the copies we control within 30 days, unless a law requires us to keep something, and we tell you what and why. Copies already delivered into your own systems (your email, your phone, your calendar) are yours to keep or delete.
  7. Showing our work. We give you the information needed to show these terms are kept, and we contribute to audits and inspections by you or an auditor you mandate, on reasonable notice, at your cost where it goes beyond the records we already keep.
  8. Breaches. If your callers' data is lost, destroyed, altered, disclosed or accessed without authority, we tell you without undue delay and at the latest 48 hours after we become aware, then keep you updated as we learn more. Tolga is the incident owner.

Sub-processors of callers' data

Cloudflare, Inc. (US): hosting, storage, and the model that drafts the callback text when a caller hangs up in silence. ElevenLabs, Inc. (US): speech, voice, and the conversation itself, which runs on a large language model through ElevenLabs' platform (today Anthropic's Claude); ElevenLabs keeps audio and transcript for 90 days. Anthropic, PBC (US): fallback for that callback draft when Cloudflare's model is unavailable. Twilio Inc. (US): telephony, and text messages to you where your line supports them; it keeps the call's numbers and times as carriers do. Plus Five Five, Inc., trading as Resend (US): delivers your message emails; our send log keeps the recipient and the subject line, which may carry a caller's name, until you ask us to delete it. Telegram Messenger Inc.: the caller's name and number reach Tolga's phone for the missed-call rescue. If you connect Google Calendar or Square yourself, they receive booking details as your own providers, on your own terms with them.

Not sub-processors of callers' data

Stripe bills your subscription and never receives a caller's data; card details never reach us.

Where the data goes

To the United States, where we and our providers operate. Before we receive any of your callers' data, including test calls during setup, the transfer safeguard is completed and signed: for a UK business, the EU standard contractual clauses (module two, controller to processor) with the ICO's International Data Transfer Addendum; for a business in Ireland or elsewhere in the EU, the same clauses without the addendum. Our sub-processors are bound by their own data-processing agreements and onward-transfer safeguards, which we hold and show you on request.

Deletion

Call records, audio and transcripts: 90 days after the record was last written. Messages: up to twelve months after the call. The email queue holds a message for at most seven days. Bookings and your business record: for the life of your subscription, then deleted at end of service as above. Your account data: twelve months after your subscription ends, except billing records kept as long as tax law requires. Earlier on request, in writing.

Your side

You confirm you have the right to have your calls answered and transcribed, you tell your callers whatever your own law requires beyond the receptionist's opening disclosure, and you keep your own lawful basis in place for anything you ask us to process.

Liability and law

As in the terms: governed by the law of the State of Florida, without prejudice to protections your local law gives that cannot be excluded. Company: OdileUSA L.L.C., 7901 4th St N Ste 300, St. Petersburg, FL 33702, United States. Contact: hello@odilelabs.com.