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Privacy Policy

Last Updated: December 1, 2025

This Privacy Policy ("Policy") explains how Douglas Broughton, doing business as ServiceRelay ("ServiceRelay", "we", "our", or "us") processes Personal Data (defined below) of individuals who access or use our Website or Services or otherwise engage with ServiceRelay.

This Policy also explains your rights and choices about how we use your Personal Data, including how you may access or update certain information about you. Where processing is based on consent, and to the extent permitted by law, by using the Services or otherwise engaging with ServiceRelay, you consent to the use of your Personal Data as described in this Policy.

1. Definitions and Scope

(a) Definitions

In this Policy, "Personal Data" means any information relating to an identified or identifiable individual, such as an individual's name, address, telephone number, or email address. In certain jurisdictions, this may also be referred to as "Personal Information." Other capitalized terms not defined herein shall have the meanings ascribed to them in our Terms of Service, available at servicerelayhq.com/terms.

(b) Scope

This Policy applies to all instances in which ServiceRelay acts as a data controller under applicable laws, including where ServiceRelay provides Services to business customers. We process call data and caller information on behalf of our business customers to provide our AI-powered after-hours answering service.

2. Categories of Personal Data We Collect

(a) Personal Data You Provide to Us

• Account & Contact Details. When you set up an account to use our Services, we collect your business name, owner name, email address, phone number, business address, industry, and account preferences.
• Emergency Contact Information. We collect emergency contact names and phone numbers that your AI assistant will contact when urgent situations are detected. Important: Emergency contacts may be called by the AI assistant during emergency situations to immediately notify them of urgent customer needs.
• Call Transcripts and Audio Data. We collect and store text transcripts of calls handled by your AI assistant. In future releases, we may also store audio recordings of these calls. This includes caller voice data, phone numbers, and any information the caller shares during the conversation.
• AI Assistant Configuration. We collect information about how you configure your AI assistant, including business hours, services offered, dispatcher name preferences, and custom instructions.
• Feedback/Communications. If you contact us for support, we collect your name, email address, phone number, the contents of your messages, and other information you choose to provide. When we send you emails, we may track whether you open them to improve our Services.
• Payment Details. When you subscribe to our paid Services, our third-party payment processor, Stripe, collects and processes your payment information, such as your name, email, billing address, and credit/debit card information. We do not see or store your credit card numbers - only Stripe customer IDs. Please consult Stripe's privacy policy.

(b) Personal Data We Collect Automatically

• Device Information. We collect information about the device you use to access our Services, including IP address, web browser type, and operating system.
• Usage Information. We collect information about your interactions with our Services, including the features you use, pages you visit, and dates and times of your visits.

(c) Personal Data We Collect from Third Parties

• Third-Party Logins. If you choose to register or log in using Firebase Authentication (phone or email), we receive your phone number or email address and Firebase user ID.
• Service Provider Data. We receive call transcripts, audio recordings, and caller information from ElevenLabs (our AI voice platform provider) when calls are handled by your AI assistant.

3. How We Use Your Personal Data

We process your Personal Data for the following purposes:

Purpose	Description	Legal Basis
Providing the Services	We process your Personal Data to provide the AI answering service you request, including handling calls, detecting emergencies, and sending notifications.	Performance of a contract
Call Analytics and Reporting	We analyze call transcripts to provide monthly performance reports and improve your AI assistant's responses. We do not use this data for marketing or to train AI models for other customers.	Legitimate interest in service improvement
Emergency Detection and Notification	We analyze call content to detect emergency situations and notify you or your designated emergency contact immediately.	Performance of a contract
Communicating with You	We send you daily call summaries at 8am in your local timezone, service updates, and respond to your support requests.	Performance of a contract and legitimate interest
Billing and Payment Processing	We process billing information to charge for our Services and maintain payment records.	Performance of a contract
Security and Fraud Prevention	We implement security measures including rate limiting, authentication, and monitoring to protect against fraud and unauthorized access.	Legitimate interest in security
Legal Compliance	We may process your Personal Data to comply with legal obligations, respond to law enforcement requests, or enforce our Terms of Service.	Legal obligation

What We Do NOT Do With Your Data

• We do NOT sell your personal information to third parties
• We do NOT use your data for marketing purposes
• We do NOT use your call data to train AI models for other customers
• We do NOT use cookies, analytics, or tracking pixels on our website
• We do NOT participate in advertising or retargeting
• We do NOT use voice data for biometric identification or verification

4. Data Recipients and Third-Party Services

We share your Personal Data with the following third-party service providers who help us deliver our Services:

Service Provider	Purpose	Data Shared
ElevenLabs	AI voice platform	Business info, phone numbers, AI assistant configuration, call audio/transcripts
Twilio	SMS notifications	Phone numbers, message content
Google Cloud Platform	Hosting and database	All customer and call data
Google Vertex AI (Gemini)	Call transcript analysis	Call transcripts (for extracting caller details)
Stripe	Payment processing	Name, email, billing information
Firebase (Google)	Authentication	Email address, phone number
Email Provider (SMTP)	Email delivery	Email addresses, daily summary content

Other Disclosures

• As Required By Law. We may disclose your Personal Data to law enforcement, regulatory bodies, or pursuant to legal process if required by law or to protect rights, property, or safety.
• Business Transfers. In the event of a merger, acquisition, or sale of assets, your Personal Data may be transferred to the acquiring entity.

5. International Data Transfers

Our Services are hosted on Google Cloud Platform in the United States. If you access our Services from outside the United States, your Personal Data will be transferred to, stored, and processed in the United States.

While we primarily serve customers in the United States, we can accept international customers. For customers outside the U.S., we rely on your consent for international data transfers. Please note that data protection laws in the United States may differ from those in your country.

6. Data Retention

We retain your Personal Data for as long as necessary to provide our Services and fulfill the purposes described in this Policy:

• Active Accounts: We retain all call transcripts, audio recordings, and account data for the duration of your subscription.
• After Cancellation: We retain your data for 30 days after subscription cancellation to allow for reactivation and to resolve any disputes.
• Account Deletion: When you request account deletion, we delete all Personal Data within 30 days, except where we are required by law to retain certain information.
• Anonymized Data: We may retain anonymized data (with no customer or caller identifying information) indefinitely for analytics purposes.

7. Cookies and Tracking Technologies

We do not use cookies, analytics, or tracking technologies on our website.

Our Services use only essential session authentication (via Firebase) to allow you to log in and use the platform. We do not use Google Analytics, advertising cookies, or any third-party tracking pixels.

8. Your Rights and Choices

Depending on your location, you may have the following rights regarding your Personal Data:

Data Subject Rights

• Access Your Data: Request a copy of the Personal Data we maintain about you.
• Correct Your Data: Request to update inaccurate information. You can update most information directly in your account Settings.
• Delete Your Account: Request account deletion (available via Settings or by contacting support@servicerelayhq.com). All Personal Data will be deleted within 30 days.
• Download Your Data: Request a download of your call history, transcripts, and account information by contacting support@servicerelayhq.com.
• Opt-out of SMS Notifications: Reply STOP to any SMS notification to unsubscribe.
• Unsubscribe from Emails: Click the unsubscribe link in any email, or adjust notification preferences in your account Settings.

California Residents (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what Personal Information we collect and how we use it
• Right to delete your Personal Information
• Right to opt-out of the "sale" of Personal Information (Note: We do not sell your Personal Information)
• Right to non-discrimination for exercising your privacy rights

How to Exercise Your Rights

To exercise any of these rights, please contact us at:

• Email: support@servicerelayhq.com
• Subject Line: "Privacy Request - [Your Request Type]"
• Include: Your account email address and specific request

We will respond to your request within 30 days. We may ask you to verify your identity before fulfilling your request.

9. Security

We implement industry-standard security measures to protect your Personal Data:

• Encryption in Transit: All data transmitted to and from our Services is encrypted using HTTPS/TLS
• Encryption at Rest: All data stored in our database (Google Firestore) is encrypted at rest
• Authentication: Firebase Authentication with JWT token validation
• Access Controls: Role-based permissions (Owner/Manager/Member) limit who can access data
• Secrets Management: All API keys and credentials stored in Google Cloud Secret Manager (not in code)
• Rate Limiting: Automatic rate limiting prevents abuse and brute-force attacks
• HMAC Validation: Webhook signatures validated with HMAC-SHA256 and timestamp verification
• SOC 2 Compliance: We are working toward SOC 2 certification to meet enterprise security standards

While we implement strong security measures, no electronic transmission or storage can be entirely secure. We cannot guarantee absolute security of your information.

10. Children's Privacy

Our Services are intended for business owners aged 18 and older. We do not knowingly collect Personal Data from children under 18.

If you are under 18, you are not permitted to use our Services or submit any Personal Data to us. If we become aware that we have collected Personal Data from a child under 18, we will delete that information immediately.

11. Voice Data and Biometric Information

Our Services involve collecting voice data from calls handled by your AI assistant. We want to be transparent about how we handle this sensitive information:

• We collect voice recordings and transcripts from callers to your business
• We do NOT use voice data for biometric identification or verification purposes
• Voice data is used solely to provide call transcripts, detect emergencies, and generate daily summaries
• Voice data is stored with the same security protections as other Personal Data
• Voice data is retained according to the retention periods described in Section 6

Depending on where you reside and how voice data is used, applicable law may define voice data as biometric data. We do not use voice data to infer characteristics about individuals beyond what is necessary to provide our Services.

12. Updates to this Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. If we make material changes, we will notify you by email or through a notice on our website.

The "Last Updated" date at the top of this Policy indicates when it was last revised. Your continued use of our Services after any changes constitutes acceptance of the updated Policy.

13. Contact Us

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