Privacy and Cookies Policy

1. 1.1Otengo is operated by Frominbox, MB (mažoji bendrija), company code 307162506, VAT LT100019538712, registered at A. Juozapavičiaus g. 28, LT-09311 Vilnius, Lithuania.
2. 1.2For anything about privacy or data protection, email info@otengo.com. We answer data protection questions within 30 days and usually much sooner.
3. 1.3We have not appointed a data protection officer. We keep that decision under review as the service grows, and the general address above reaches the person responsible.
4. 1.4Where we are required to designate a UK representative under Article 27 of the UK GDPR, we will do so and name them here.

1. 2.1For your customers’ data we are a processor. You decide who is called, why, and what the assistant says. We act on your instructions. You are the controller, and it is your privacy policy that has to tell your customers about it - not this one.
2. 2.2For your own data we are a controller. Your account, your billing, the emails we send you and the way you use the app are ours to explain, and section 4 does that.
3. 2.3For the record of who has opted out we are also a controller. This is the odd one, and it is deliberate: if that list were only held on your behalf, deleting your data would erase the only proof that somebody asked never to be called again. Keeping it protects them, not us. It contains phone numbers and nothing else.

Processed on your behalf, under the Data Processing Agreement. In outline:

1. 3.1People who call your store - their phone number, what they say, the transcript, a recording if you have switched recording on, what the call was about and how it ended, and the order or account we matched them to.
2. 3.2People we call or text for you - name, phone number, the order or delivery details the call is about, whether they have given permission to be contacted, when they were last contacted, and what happened on the call.
3. 3.3From Shopify- we read the orders, customers, products and fulfilment records your chosen features need, so the assistant can answer “where is my order” without asking the caller to recite it. We do not request access to every historical order.
4. 3.4Consent records - who agreed to be contacted, when, through which channel, and the exact wording they saw or heard. Kept because it is the only thing that answers a challenge months later.

Otengo is not built for sensitive data and you should not configure the assistant to collect it. Someone may still mention something personal on a call; where that reaches a transcript it is protected like everything else and deleted on the same schedule.

1. 5.1Callers are always told they are speaking with an AI assistant. This is not a reminder in a help page: the system will not save a greeting that leaves it out, and if a stored greeting somehow lacks it, the disclosure is added before the call connects.
2. 5.2Recording is off until the merchant switches it on, and it can only be switched on once the greeting says calls are recorded. Remove that from the greeting and recording switches itself off. Recording silently is not something this product can do.
3. 5.3You can check that claim rather than trust it. Open a trial account, take the AI disclosure out of the greeting, and try to save.
4. 5.4The reasons differ by country - several US states require everyone on a call to agree to recording, the UK requires reasonable efforts to inform people, and the EU requires the AI to be disclosed - but the behaviour is the same everywhere, because building three versions of this would mean getting one of them wrong.

1. 6.1Our suppliers, named individually at otengo.com/subprocessors, each under a written contract limiting them to our instructions. That page says what each one does and what it can see.
2. 6.2Services you connect yourself from inside the app. Those are your choice and your relationship; we send them only what the integration needs.
3. 6.3Authorities, where the law requires it. We check that a request is valid before answering it, and tell you unless we are legally prevented.
4. 6.4A buyer, if the business is ever sold - on the same terms as this policy, and we would tell you first.

1. 7.1Records are stored in the European Union: call history, transcripts, recordings, contacts, consent records, accounts.
2. 7.2Live calls are different. Audio travels through the telephone network and the speech provider as it happens, and some of that is outside the EEA. We are not going to claim everything stays in Europe, because it does not.
3. 7.3Those transfers are covered by the Standard Contractual Clauses, with the UK Addendum for UK data, and we keep a written risk assessment for each provider. Where a supplier also holds an EU-US Data Privacy Framework certification we treat it as an extra safeguard, not the main one.

These periods are enforced by a job that runs every day, not by anyone remembering. A table holding personal data that is not on that job’s list is treated as a defect.

1. 9.1Encrypted in transit and at rest, backups included.
2. 9.2Recordings sit in private storage and are reachable only through short-lived links issued after a permission check.
3. 9.3Each store’s data is isolated at the database level, so one merchant cannot read another’s even if application code is wrong.
4. 9.4Access is limited to the few people who need it, with individual accounts and strong authentication, and any access to a merchant’s account is logged.
5. 9.5Personal data is never written to our application logs - no transcripts, phone numbers, names or whole payloads. Identifiers and metrics only.
6. 9.6More detail is on our security page.

1. 10.1Deleting a call deletes the recording and the transcript, including the copy held by our speech provider. A promise that data is gone is worth nothing if it only covers our own database.
2. 10.2Uninstalling deletes your customers’ data within 48 hours, automatically.
3. 10.3Before you go, you can export your call records and contacts yourself.
4. 10.4The suppression list survives deletion, on purpose, for the reason in section 2.

As a merchant, in relation to your own data, you can ask for a copy, correction, deletion, a portable export, or restriction, and you can object to processing based on legitimate interests. Email info@otengo.com. There is no charge and we respond within 30 days.

For your customers’ data, the requests come to you - you are the controller. Most of what you need is in the app already, and we help with the rest.

If an Otengo number called you, the store that called is responsible for deciding to do so, and we placed the call for them. You can stop all future calls immediately, ask for the recording, or ask for it to be deleted. How to do each is on the page for people who received a call, in plain language and without needing an account.

Saying “stop” on the call itself is the fastest way, and it is acted on straight away rather than at the end of the campaign.

1. 13.1Tell us first if you can - info@otengo.com. Most complaints are faster to fix than to escalate.
2. 13.2Lithuania and the EU - our lead authority is the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija). You may also complain to the authority where you live.
3. 13.3United Kingdom - the Information Commissioner's Office (ICO), at https://ico.org.uk/make-a-complaint/ or 0303 123 1113.
4. 13.4United States - unwanted calls can be reported to the Federal Communications Commission (FCC), and other complaints to the Federal Trade Commission (FTC) or your state attorney general.

1. 15.1The date at the top is the current version. Material changes are notified in the app before they take effect.
2. 15.2If a change affects how your customers’ data is handled, we tell you in time to look at it, because you may need to update your own privacy policy.