Privacy Policy

1. Who we are

The controller of personal data is Fundacja Rozwoju Przedsiębiorczości „Twój StartUp”, registered office at ul. Żurawia 6/12 lok. 766, 00-503 Warszawa, Poland. Correspondence address: al. Jerozolimskie 123a, 02-017 Warszawa, 18th floor, Atlas Tower.

Entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw, 12th Commercial Division, under KRS 0000442857. NIP 5213641211, REGON 146433467.

Clupp AI is operated as an organised part of that foundation’s enterprise. For data protection matters: glebbalabanovpl@gmail.com.

2. Two different roles

We process personal data in two distinct capacities, and it matters which one applies to you.

As a controller, we process the data of people who visit this website, send us a request through the form, or represent a company we have a contract with. That processing is what this policy describes.

As a processor, we handle the call recordings, transcripts and everything else our clients upload into the service. For that data the controller is the client company, not us — we act on its documented instructions under a separate data processing agreement.

So if you spoke with a company that uses Clupp AI, or you work there, your requests should go to that company. If a request reaches us instead, we forward it to them.

3. What we collect on this website

The trial request form asks for your name, work email address and company. Your website, your telephony provider and a free-text comment are optional. We use this only to reply and to arrange the trial.

The form sends the information to us by email. We do not sell it, do not add you to a marketing list, and do not use it for anything beyond answering your request.

Our hosting provider records standard technical logs, including IP addresses, which are needed to serve the site and keep it secure.

4. Cookies and local storage

This website sets no analytics, advertising or tracking cookies.

The only thing kept in your browser is the interface language you selected, stored locally so the site opens in the same language next time. It is never sent to us and identifies no one.

5. Data inside the Clupp AI service

When a client company uses the service, the following may be processed on its behalf: call recordings and audio files, transcripts, call metadata, data about that company’s sales reps, data about the people who spoke with them, and the results of the analysis — scores, summaries, reports and statistics.

That data belongs to the client company. We process it solely in order to provide the service and do not use it for our own purposes.

6. Legal grounds

Answering your enquiry and performing a contract — Art. 6(1)(b) GDPR.

Our legitimate interest in operating the site securely, contacting the representatives of contracting parties, and establishing or defending legal claims — Art. 6(1)(f) GDPR.

Legal obligations, in particular accounting and tax record-keeping — Art. 6(1)(c) GDPR.

Where we act as a processor, the legal ground for the processing is determined by the client company as the controller.

7. Who we share data with

We rely on external providers to run the service. They may access data only to the extent necessary and are bound by data processing agreements.

The categories are: cloud hosting and infrastructure, database and file storage, providers of the AI language models used to analyse calls, email delivery, and error monitoring and security services.

We may also disclose data to public authorities where the law requires it, and to our legal and accounting advisers.

Clients receive the current list of named subprocessors under their data processing agreement. Anyone else can request it at glebbalabanovpl@gmail.com.

8. Transfers outside the EEA

Some of those providers may process data outside the European Economic Area. Where that happens we rely on an adequacy decision of the European Commission, or on the Standard Contractual Clauses issued by the Commission, together with additional safeguards where they are needed.

9. How long we keep data

Data from the request form: for as long as we are discussing the trial with you, and afterwards until any claims arising from it become time-barred.

Contract data: for the term of the contract, and afterwards for as long as accounting and tax law requires.

Data processed on behalf of a client: as agreed in the data processing agreement. After the contract ends, the client may ask for their data in a technically available format; we delete it afterwards, except where the law requires further retention.

10. Artificial intelligence and automated decisions

The service analyses calls using AI language models, including models supplied by third parties. The results are analytical and advisory in nature. They may contain errors, omissions or statements that do not match the facts, and they have to be verified before they are acted on.

The system is not designed to decide on its own about hiring, dismissal, promotion, pay, or any sanction against an employee. Decisions of that kind stay with the client company and require human judgement.

We do not profile visitors of this website.

11. Your rights

You have the right to access your data, to have it rectified, to have it erased, to restrict its processing, to receive it in a portable format, and to object to processing based on our legitimate interest.

To exercise any of these, write to glebbalabanovpl@gmail.com. If your data is processed inside the service on behalf of one of our clients, we will pass your request on to that company as the controller.

You also have the right to lodge a complaint with the supervisory authority — the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warszawa.

12. Security

Access to the service is granted per user and scoped by role: a head of sales sees their department, a sales rep sees only their own calls and their own coaching. Data travels over encrypted connections and is stored with providers that maintain recognised security standards.

In the event of a personal data breach we act under Art. 33 and 34 GDPR and, where we act as a processor, notify the client company without undue delay.

13. Changes to this policy

We may update this policy when the service or the law changes. The current version is always published on this page, with the date it was last updated.

14. Contact

Questions about this policy or about your data: glebbalabanovpl@gmail.com.

By post: Fundacja Rozwoju Przedsiębiorczości „Twój StartUp”, al. Jerozolimskie 123a, 02-017 Warszawa, 18th floor, Atlas Tower.