Privacy policy
Preview: details in square brackets are filled in before launch. This policy describes the planned service and is checked against the services actually used before launch.
1. Controller
The controller for this website under Art. 4(7) GDPR is „Raboti“ DPK (Работи ДПК), ul. Yordan Badev 8B, et. 1, ap. 17, 1700 Sofia, Bulgaria. Email: hello@stemvo.eu, phone: [Telefonnummer]. Data protection officer: [Name und Kontakt der/des Datenschutzbeauftragten, falls bestellt]
2. Two roles: website and phone assistant
We are the controller for data from visits to this website and from your contact with us. For data from calls to our customers, the business using the phone assistant is the controller. We process that call data only on its behalf and instructions, under a data processing agreement (Art. 28 GDPR).
3. Website visits and server logs
Our hosting provider processes technically necessary data when you visit: IP address, date and time, page, data volume, referrer, browser and operating system, to deliver the site and keep it secure (Art. 6(1)(f) GDPR). Logs are deleted after 14 days at most unless needed for a specific security incident. Hosting provider: [Hosting-Anbieter, Sitz, Serverstandort].
4. No cookies, no tracking
This website uses no cookies, no analytics or marketing tools and no social media plugins. Nothing is stored on or read from your device beyond what is strictly necessary to show the page you asked for. Fonts, audio and all other files load from our own server.
5. Contacting us
If you contact us, we process your name, contact details and message to reply (Art. 6(1)(b) GDPR where it concerns a contract, otherwise Art. 6(1)(f)). We delete the data once your request is closed and no legal retention duty applies.
6. Customer accounts and billing
Customers create an account to use the service. We process company details, contact persons, login, usage and billing data (Art. 6(1)(b) GDPR) and keep accounting records for the statutory retention period (Art. 6(1)(c)). Payments are handled by [payment provider].
7. Call data processed on behalf of customers
When you call a business that uses our phone assistant, we process on its behalf your phone number, time and length of the call, a transcript, a summary, details you give during the call and, if the business enabled it, an audio recording.
- AI notice: the assistant tells you at the start that you are talking to an AI system (Art. 50(1) EU AI Act).
- Recording: only if the business enabled it, and the assistant says so at the start of the call.
- Location: call data is stored in the European Union.
- Retention: the business sets how long recordings, transcripts and summaries are kept; they are then deleted automatically.
- Your rights: for access, correction, deletion or objection regarding call data, contact the business you called. We help it respond.
8. Sub-processors and transfers outside the EU
We use carefully selected sub-processors for telephony, speech recognition, the language model, voice output and hosting; see the data processing agreement. We process data in the EU. Any transfer outside the EU would rely only on an adequacy decision or standard contractual clauses (Art. 45 and 46 GDPR).
9. No automated decisions
The phone assistant makes no decisions with legal or similarly significant effects on you (Art. 22 GDPR). It takes down requests, answers questions and books appointments under the business's rules.
10. Your rights
You have the right of access (Art. 15 GDPR), rectification (16), erasure (17), restriction (18), portability (20) and to withdraw consent (7(3)). Email hello@stemvo.eu.
Right to object (Art. 21 GDPR): where we process data on the basis of legitimate interests, you may object at any time on grounds relating to your particular situation. We will then stop unless we show compelling legitimate grounds or need the data for legal claims.
You may complain to a data protection authority, in particular where you live or work (Art. 77 GDPR). Our lead authority: Commission for Personal Data Protection (CPDP), 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, Bulgaria.
11. Security and changes
The site is served over HTTPS only. Call data is encrypted in transit and at rest, with access limited to authorised people. We update this policy when our service or the law changes; the version on this page applies.