Privacy Policy

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Privacy Policy

Last updated: May 1, 2026

Introduction

We respect the privacy of our customers and other interested individuals and comply with applicable laws on the protection of your privacy, in particular the General Data Protection Regulation of the European Union ("GDPR") and the German Federal Data Protection Act (BDSG).

This Privacy Policy applies to the website www.famulor.io and the B2B web application available at app.famulor.de (the "Service").

The following categories of data subjects are covered by this Privacy Policy:

  • Website visitors
  • Users of the Famulor B2B web application
  • Recipients of test calls or interactions with the Famulor AI telephone assistant
  • Contacts and recipients of calls placed by our customers via the Famulor Platform (where Famulor acts as data processor)

The controller responsible for the processing of your personal data within the meaning of this Privacy Policy is:

BEK Service GmbH Westendstr. 2A D-87439 Kempten (Allgäu) Germany Email: support@famulor.io

This Privacy Policy explains:

  • the purposes for which personal data is collected and processed,
  • the categories of personal data concerned,
  • the legal basis for processing,
  • the processors and third parties involved,
  • transfers of personal data to third countries,
  • retention periods, and
  • your rights as a data subject.

1. What categories of personal data do we collect about you?

Depending on how you interact with the Service, we may process the following categories of personal data:

  • Identification data: first name, last name, salutation
  • Contact data: email address, telephone number, postal address
  • Company data: company name, position, VAT ID, billing address
  • Account data: login data, password (in hashed form), settings, configurations
  • Content and communication data: call scripts, prompts, audio recordings, transcripts, knowledge-base content, support requests, email correspondence
  • Usage data: access times, features used, API calls, error logs, IP address, browser, device, operating system
  • Marketing data: newsletter subscriptions, interactions with newsletters, conversion data
  • Payment data: invoice data, payment status (full payment data is processed by our payment service provider — see Section 5)

2. How do we obtain personal data about you?

We obtain personal data:

  • when you fill in contact, demo or onboarding forms on our website,
  • by email at support@famulor.io,
  • when you create or use a Famulor account,
  • when you book an online appointment via Cal.com,
  • when you test our AI telephone assistant on the website,
  • when you subscribe to our newsletter,
  • via cookies and similar technologies on the website (subject to consent where required),
  • when third parties (e.g., partners or referrers) lawfully share your data with us.

3. Purposes of processing on the website www.famulor.io

3.1 Website hosting

Our website is built with the Next.js framework and hosted on Vercel. Vercel is a cloud-hosting service of Vercel Inc., a U.S. company; our hosting infrastructure is located in the EU (region fra1, Frankfurt). Vercel uses CDN providers (e.g., Cloudflare and AWS CloudFront) to deliver content efficiently and securely.

  • Data processed: technical information such as IP address, device, browser, log data, cookies.
  • Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the secure provision of the website); Art. 6(1)(a) GDPR (consent for non-essential CDN/analytics features); EU-U.S. Data Privacy Framework and Standard Contractual Clauses for transfers to the U.S.
  • Processors involved: Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA.
  • Further information: Vercel Privacy Policy.

3.2 Testing the AI telephone assistant

We provide a function on our website that allows you to test our AI telephone assistant. After entering the necessary details, you receive a call from our AI assistant. Test calls are recorded for quality-assurance purposes. Use of this feature may involve transfers to third countries.

  • Data processed: identification data, company, contact data, voice and other information you transmit.
  • Legal basis: Art. 6(1)(f) GDPR; EU-U.S. Data Privacy Framework; Standard Contractual Clauses.
  • Processors involved: LiveKit Inc. (USA), Twilio Ireland Ltd. (Ireland), Eleven Labs Inc. (USA), Deepgram Inc. (USA), OpenAI L.L.C. (USA), PostHog Inc. (USA), Microsoft Ireland Operations Ltd. (Ireland), AWS — A100 ROW GmbH (Germany).
  • Further information: please do not transmit special categories of personal data (Art. 9 GDPR — e.g., ethnic origin, political opinions, religion, union membership, genetic data, biometric data, health, sexual life). You can avoid the processing of your data by not using the test feature.

3.3 Contact via email

We publish a contact email address on our website to enable inquiries.

  • Data processed: email address, communication content.
  • Legal basis: Art. 6(1)(f) GDPR (responding to inquiries) or Art. 6(1)(b) GDPR (pre-contractual measures).
  • Further information: please do not transmit special categories of personal data (Art. 9 GDPR).

3.4 Newsletter

You can subscribe to our newsletter on our website to receive regular updates.

  • Data processed: identification data, contact data, interaction data, cookies.
  • Legal basis: Art. 6(1)(a) GDPR (consent); EU-U.S. Data Privacy Framework; Standard Contractual Clauses.
  • Processors involved: MailerLite, Inc., 548 Market St, PMB 98174, San Francisco, CA 94104-5401, USA.
  • Further information: MailerLite Privacy Policy and DPA. You may unsubscribe at any time via the link in each newsletter or by contacting support@famulor.io.

3.5 Online appointment booking

You can book an meeting on our website via Cal.com. Use of this feature may involve transfers to third countries.

  • Data processed: identification data, contact data, company data, monthly call volumes, free-text information, technical information, cookies.
  • Legal basis: Art. 6(1)(a) GDPR (consent); EU-U.S. Data Privacy Framework.
  • Processors involved: Cal.com Inc. (USA).
  • Further information: Cal.com Privacy Policy. You can avoid this processing by not booking an appointment online.

3.6 Analysis of user behavior

We use the following technologies to analyze and improve user behavior, monitor and optimize advertising campaigns, and acquire new customers. Use of these features may involve transfers to third countries.

  • Google Analytics, Google Tag Manager
  • TikTok Pixel, Meta Pixel, LinkedIn Pixel

Data processed: technical information (IP address), browser data, behavioral and interaction data, device information, event data, conversion data, cookies.

Legal basis: Art. 6(1)(a) GDPR (consent); EU-U.S. Data Privacy Framework.

Processors involved: TikTok Technology Ltd. (Ireland), Meta Platforms Ireland Ltd. (Ireland), LinkedIn Ireland Unlimited Company (Ireland), Google Ireland Ltd. (Ireland).

Further information: TikTok, Meta, LinkedIn, Google.

3.7 Display of third-party content via plug-ins and widgets

We have integrated social-media plug-ins and widgets (e.g., Facebook plug-ins, YouTube embeds) on our website to display content of interest, improve user experience and optimize advertising. Use may involve transfers to third countries.

  • Data processed: technical information (IP address), browser data, page-view and interaction data, location data, cookies.
  • Legal basis: Art. 6(1)(a) GDPR (consent); EU-U.S. Data Privacy Framework.
  • Processors involved: Meta Platforms (USA/Ireland), Google Ireland Ltd. (Ireland).
  • Further information: Facebook Plug-ins, Facebook Privacy, Google Privacy.

3.8 Google Fonts

We use the Google Fonts service to display fonts on our website.

  • Data processed: IP address, browser information, font usage, page-view data, cookies.
  • Legal basis: Art. 6(1)(a) GDPR (consent); EU-U.S. Data Privacy Framework.
  • Processors involved: Google Ireland Ltd. (Ireland).
  • Further information: Google Privacy Policy.

4. Purposes of processing in the B2B web application app.famulor.de

4.1 App hosting

Our B2B web application is hosted on AWS infrastructure provided by A100 ROW GmbH in the EU.

  • Data processed: technical information (IP address), device information, behavior data relevant for error analysis.
  • Legal basis: Art. 6(1)(b) GDPR (performance of contract or pre-contractual measures).
  • Processors involved: AWS — A100 ROW GmbH (Germany).
  • Data center location: EU.
  • Further information: AWS Privacy Notice.

4.2 Provision of the Service — configuring and managing AI voice assistants

  • Data processed: AI prompts and other AI-related data, configurations, technical access data (e.g., API keys), telephone numbers.
  • Legal basis: Art. 6(1)(b) GDPR.
  • Processors involved: AWS — A100 ROW GmbH (Germany); see Section 5 for additional providers used in the AI/voice processing chain.
  • Data center location: EU.

4.3 Customer relationship management (CRM)

  • Data processed: identification data, contact data, email correspondence data.
  • Legal basis: Art. 6(1)(b) GDPR; Art. 6(1)(f) GDPR (legitimate interest in customer relationship management).

4.4 Account creation and billing

  • Data processed: company name, contact person, email address, telephone number, billing address, payment data.
  • Legal basis: Art. 6(1)(b) GDPR; Art. 6(1)(c) GDPR (compliance with legal obligations, e.g., bookkeeping).

4.5 Usage data

  • Data processed: login/logout times, feature usage, API calls, error logs.
  • Legal basis: Art. 6(1)(b) GDPR (provision of the Service); Art. 6(1)(f) GDPR (legitimate interest in security and improvement).

4.6 Customer data uploaded to the Service (call recipients)

When you use the Famulor Platform, you may upload personal data of third parties (e.g., contact lists). With respect to this data, you act as the controller and Famulor acts as the processor pursuant to Art. 28 GDPR. The applicable Data Processing Agreement is available at https://www.famulor.io/dpa. You are responsible for ensuring the lawfulness of this processing, including consent and information obligations vis-à-vis your contacts.

5. Third-party providers and infrastructure

To provide the Service, we work with various third parties. The most important categories are listed below.

5.1 Infrastructure & hosting

  • Amazon Web Services (AWS) — cloud hosting and storage (data center: EU); contracted via A100 ROW GmbH, Germany.
  • Vercel — frontend hosting and CDN; primary hosting region Frankfurt, Germany (fra1).
  • Twilio — communications API and telephony services via Twilio Ireland Ltd., Dublin.

5.2 AI model providers (EU-GDPR compliant)

Important notice: we do not use the public OpenAI API. We exclusively use Microsoft Azure OpenAI Service, which guarantees EU data processing, GDPR compliance, and that your data is not used for model training.

  • OpenAI GPT models — exclusively via Microsoft Azure OpenAI Service with Azure Data Zones in the EU. Region: EU. GDPR status: fully compliant. Guarantee: data not used for model training.
  • Google Gemini — via Google Vertex AI with EU data residency. Region: EU.
  • Anthropic Claude — with EU-compliant data processing. Region: EU.
  • Meta Llama — open-source model hosted on Microsoft Azure. Region: EU.
  • ElevenLabs — text-to-speech via Enterprise variant with EU data residency. Region: EU.
  • Gladia — speech-to-text. Region: EU.
  • Deepgram — speech-to-text. Region: EU/U.S. depending on the application; Standard Contractual Clauses apply.

5.3 Analytics

  • PostHog — product analytics (EU-hosted instance).
  • Google Analytics — web analytics (with EU data processing).
  • Meta/Facebook Analytics, TikTok Pixel, LinkedIn Pixel — marketing analytics (EU-based subsidiaries).

5.4 Payments

  • Stripe Payments Europe Ltd. — payment processing via European subsidiary in Dublin, Ireland.

A complete and current list of our processors and sub-processors can be obtained free of charge by sending a written request to support@famulor.io.

6. Disclosure of personal data

We may disclose personal data to:

  • service providers and processors (hosting, AI/voice, email, analytics, payments — see Section 5);
  • our professional advisors and auditors;
  • competent authorities and courts where required by law;
  • acquirers in the context of corporate transactions, subject to appropriate confidentiality safeguards.

We do not sell your personal data to third parties.

7. Transfer of personal data to third countries

Personal data may be transferred to countries outside the European Economic Area when stored or processed by our providers. In such cases we ensure an adequate level of data protection by:

  • relying on adequacy decisions of the European Commission (e.g., EU-U.S. Data Privacy Framework where applicable),
  • entering into the EU Standard Contractual Clauses (SCCs) under Implementing Decision (EU) 2021/914, and
  • implementing supplementary technical and organizational measures where necessary.

A copy of the safeguards used can be requested from support@famulor.io.

8. Retention periods

As a general rule, we retain your personal data only for as long as necessary for the purposes set out in this Privacy Policy:

  • Website usage data and log files: generally up to 12 months;
  • Contact form data: up to 24 months after the inquiry is closed;
  • Account data: for the duration of the contract plus statutory retention periods (in particular 6 years under § 257 HGB and 10 years under § 147 AO);
  • Payment and accounting data: 10 years (§ 147 AO);
  • Newsletter data: until your unsubscribe;
  • Test-call recordings: as required for quality assurance purposes, generally up to 90 days;
  • Customer-uploaded data (controller data): in accordance with the DPA and your instructions; deletion within 30 days after termination of the contract.

After expiration of the retention period, we delete or anonymize your personal data unless we are subject to a longer statutory retention obligation or another legal basis.

9. Data security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, loss or destruction, including encryption, access controls, regular reviews, employee training, and contractual safeguards with our processors.

10. Your rights as a data subject

You have the following rights:

  • Right of access (Art. 15 GDPR) — to receive information about the personal data we process about you;
  • Right to rectification (Art. 16 GDPR) — to have inaccurate personal data corrected;
  • Right to erasure (Art. 17 GDPR) — to request the deletion of your personal data, subject to the conditions of the GDPR;
  • Right to restriction of processing (Art. 18 GDPR);
  • Right to data portability (Art. 20 GDPR);
  • Right to object (Art. 21 GDPR), in particular against processing based on legitimate interests or for direct marketing;
  • Right to withdraw consent (Art. 7(3) GDPR), with effect for the future;
  • Right to lodge a complaint with a supervisory authority (Art. 77 GDPR), in particular in your country of residence, your place of work or the place of the alleged infringement. Our competent supervisory authority is the Bavarian State Office for Data Protection Supervision (Bayerisches Landesamt für Datenschutzaufsicht, BayLDA), Promenade 27, 91522 Ansbach, Germany.

To exercise your rights, please contact us at support@famulor.io. We will respond within the legally required period (generally one month, extendable by two months for complex requests).

11. What happens if you do not provide personal data?

If you choose not to provide personal data or object to its processing, we will respect this choice in accordance with our legal obligations. However, we will then not be able to perform the actions necessary to achieve the purposes described in this Privacy Policy (e.g., we cannot create an account or provide the Service).

12. Cookies

We use cookies and similar technologies on our website. Detailed information about the cookies used, their purposes and retention periods is available in our cookie banner / cookie settings, where you can also withdraw or change your consent at any time.

Cookie categories:

  • Essential cookies — required for the operation of the Service (e.g., session, security). Legal basis: Art. 6(1)(f) GDPR or Art. 6(1)(b) GDPR; § 25(2) TTDSG.
  • Analytics cookies — to analyze usage and improve the Service. Legal basis: Art. 6(1)(a) GDPR; § 25(1) TTDSG.
  • Marketing cookies — to display personalized advertisements. Legal basis: Art. 6(1)(a) GDPR; § 25(1) TTDSG.

13. Automated decision-making and profiling

The Service may use AI models to generate voice and text responses. This is not "automated individual decision-making" within the meaning of Art. 22 GDPR with legal effects on you. To the extent your contacts interact with our AI assistants, you (as the controller) must inform them of the use of AI as required by Art. 13/14 GDPR and the EU AI Act.

14. Data Protection Officer

For questions regarding the processing of your personal data or this Privacy Policy, please contact our Data Protection contact at:

Email: support@famulor.io Postal address: BEK Service GmbH, Westendstr. 2A, D-87439 Kempten (Allgäu), Germany.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, e.g., to reflect changes in legislation or our processing activities. The current version is always available at https://www.famulor.io/privacy. Material changes will be communicated by email or through the Service.

16. Contact

For any other questions about data protection at Famulor:

BEK Service GmbH Westendstr. 2A D-87439 Kempten (Allgäu) Germany Email: support@famulor.io

Data Processing Addendum (DPA)

For companies that wish to enter into a Data Processing Agreement with Famulor, we provide a standardized Data Processing Addendum.

Request Data Processing Addendum (DPA)

Through the form, you can enter your company details and will receive the agreement for review and signing via email.