Privacy Policy
This privacy policy describes how claiverly GmbH processes personal data in connection with the website and the VoiceBooker platform. VoiceBooker is a platform for creating, configuring and managing VoiceBots/VoiceAgents and chatbots. Depending on the booked scope of services, telephony, automation, analytics, CRM and messaging integrations, in particular WhatsApp Business, may also be integrated.
1. Controller
claiverly GmbH
Am See 1a
01067 Dresden
Germany
Email: privacy@claiverly.de
Website: https://claiverly.de
2. Who this privacy policy applies to
This privacy policy applies in particular to:
- visitors to our website
- contact persons at prospective customers, customers, partners and suppliers
- registered users of the platform
- persons who communicate with us by email, contact form, support channel, test function, VoiceBot, chatbot or via messaging channels
- persons whose data is entered into the platform by customers as part of our services
3. Our data protection role
We process personal data partly as a controller and partly as a processor.
As a controller, we act in particular when processing data in connection with our website, contact requests, pre-contractual communications, user accounts, contract performance, billing, security, our own support and our own product information.
To the extent that customers use our platform to deploy VoiceBots/VoiceAgents, chatbots, telephony workflows or WhatsApp Business communication vis-a-vis their end customers, prospects or employees, the respective customer is generally the data controller. In these cases, we generally process personal data only on behalf of the customer, under the customer's instructions and on the basis of a separate data processing agreement.
If you interact with a bot or communication workflow of one of our customers and have questions about the specific legal basis, retention period or substantive use of your data, please contact the respective customer first. We support our customers in fulfilling their data protection obligations where this is contractually and technically possible for us.
4. Sources and categories of personal data
We receive personal data:
- directly from you, for example when you contact us, register, submit support requests, or use demo or test functions
- from our customers or their authorized users when they enter data into the platform
- from connected systems and integrations that a customer links to the platform
- automatically when our website or platform is used, for example via log files and device and usage data
Depending on the use case, we process in particular the following categories of data:
- master and contact data, for example name, company, role, email address and phone number
- contract, billing and communication data
- authentication and account data
- technical usage, device, log and diagnostic data
- configuration and integration data, for example bot configurations, prompts, phone numbers, messaging IDs, API keys or interface parameters
- content data from conversations, chats, messages and support cases, insofar as they arise in the respective process
5. Please do not send sensitive data unless necessary
Please do not send us special categories of personal data within the meaning of Art. 9 GDPR via free-text fields, test functions, emails, support channels or demo requests unless this is strictly necessary and legally safeguarded. This includes, in particular, health data, biometric data, information about racial or ethnic origin, political opinions, religion, trade union membership or sex life.
If customers wish to use our platform for use cases involving such data, this must be assessed separately in advance, legally validated and configured appropriately from a technical perspective.
6. Purposes and legal bases of processing
Where we rely on Art. 6(1)(f) GDPR, our legitimate interests are in particular the secure, stable and efficient operation of the website and platform, handling requests, support and customer care, abuse and fraud prevention, error analysis and further development of our offering, as well as the assertion, safeguarding or defense of legal claims.
6.1 Access to the website, hosting and server log files
When you visit our website, we process technically necessary connection and usage data.
- Data processed: IP address, date and time of access, pages accessed, referrer, browser type, operating system, device information and log data.
- Purposes: delivery of the website, stability, attack detection, abuse prevention, error analysis and system security.
- Legal bases: Art. 6(1)(f) GDPR; where individual processing operations are required to provide requested functions, additionally Art. 6(1)(b) GDPR.
6.2 Technically required cookies, session storage, local storage and consent management
We use technically necessary storage technologies to provide the website and the login area in a functional and secure manner. This may include cookies, session storage, local storage or comparable technologies.
- Data processed: session identifiers, login status, language settings, security tokens, consent information and comparable technical entries.
- Purposes: provision of core functions, recognition of settings, protection of forms and management of your privacy preferences.
- Legal bases: Art. 6(1)(b) GDPR for contract-related functions in the user account and Art. 6(1)(f) GDPR for the secure and user-friendly operation of the website.
Where we use non-essential analytics, marketing or third-party content, this is done only after your selection in the consent banner or on the basis of any other required consent.
You can manage, restrict or delete cookies and other local storage items in your browser settings. However, this may limit certain functions of the website or platform.
6.3 Contact requests, demo requests, test functions and appointment scheduling
If you contact us, request a demo, book an appointment or use test functions offered for VoiceBots, chatbots or telephone assistants, we process the information you provide in order to handle the respective request.
- Data processed: name, company, contact details, appointment data, information about your use case, free-text details, and content from test calls or test chats insofar as you actively use such functions.
- Purposes: responding to requests, carrying out pre-contractual measures, presenting the product, organizing appointments and quality assurance.
- Legal bases: Art. 6(1)(b) GDPR insofar as the processing serves pre-contractual steps or a service requested by you; otherwise Art. 6(1)(f) GDPR. Where recordings, transcripts or further follow-up communication take place only with your consent, Art. 6(1)(a) GDPR also applies.
6.4 Newsletter, product information and service notices
If you sign up for a newsletter or consent to comparable product communication, we process your contact details and proof of your consent. We may also send existing customers contract-related service, security and product information where this is required for use of the service or otherwise legally permissible.
- Data processed: name, email address, company, consent status, double opt-in records and interaction data insofar as such data is collected when messages are sent.
- Purposes: sending newsletters, release notices, security-related communications and other product-related information.
- Legal bases: Art. 6(1)(a) GDPR for consent-based newsletters; Art. 6(1)(b) or (f) GDPR for necessary service communication.
6.5 Registration and user account
A user account is generally required in order to use the platform.
- Data processed: registration and profile data, business contact details, roles and permissions, login and authentication data, IP address, and the dates and times of registration and logins.
- Purposes: setting up and managing user accounts, authentication, prevention of misuse, access control and contract performance.
- Legal bases: Art. 6(1)(b) GDPR and Art. 6(1)(f) GDPR for security and abuse prevention measures.
6.6 Provision and operation of the platform
We process the data required to set up, configure, manage and technically operate VoiceBooker.
- Data processed: organization and account data, bot and workflow configurations, prompts, knowledge content, technical access data, phone numbers, messaging identifiers, integration parameters and other settings necessary for operation.
- Purposes: providing the booked scope of services, administering the platform, synchronization with connected systems and performance of contractual services.
- Legal bases: Art. 6(1)(b) GDPR; for additional security and operational processes, Art. 6(1)(f) GDPR.
6.7 VoiceBots, chatbots, telephony and WhatsApp Business
If the platform is used for automated communication, communication and content data may be processed. This applies in particular to VoiceBots/VoiceAgents, chatbots, telephone assistants and messaging integrations such as WhatsApp Business.
- Data processed: communication metadata, phone numbers, messaging IDs, conversation and message content, transcripts, audio recordings, timestamps, routing and status information, attachments, and evaluation or documentation data configured by the customer.
- Purposes: carrying out and documenting communication processes, handling inquiries, automating workflows, technical delivery, quality assurance, error analysis and security.
- Legal bases: where we are responsible for these processes ourselves for our own demos, support or business communication, Art. 6(1)(b) or (f) GDPR; where we process data on behalf of a customer, the respective customer determines the applicable data protection legal basis.
Recordings or transcriptions do not take place as a general rule. They occur only if the respective function is activated and a valid legal basis exists.
6.8 Support, CRM and ongoing customer care
We process data relating to contact persons at customers, prospective customers and partners in order to maintain business relationships and provide support.
- Data processed: contact details, company affiliation, communication history, support tickets, error descriptions, conversation notes and contract-related information.
- Purposes: support, handling technical questions, customer care, documentation of processes and maintenance of the business relationship.
- Legal bases: Art. 6(1)(b) GDPR and Art. 6(1)(f) GDPR.
6.9 Billing, payment processing and accounting obligations
Where paid services are used, we process the data required for invoicing, payment and accounting.
- Data processed: billing address, company and tax data, contract data, service periods, payment status, transaction references and, where applicable, data of external payment service providers.
- Purposes: billing, receivables management, compliance with statutory retention and documentation obligations.
- Legal bases: Art. 6(1)(b) GDPR, Art. 6(1)(c) GDPR and, where necessary, Art. 6(1)(f) GDPR for the assertion or defense of claims.
6.10 Security, abuse prevention, monitoring and product improvement
We process technical event, diagnostic and usage data in order to ensure the secure and stable operation of the platform and to further develop the service.
- Data processed: system and error logs, diagnostic information, usage and event data, status messages, security-related logs and pseudonymized evaluations.
- Purposes: detection and remediation of disruptions, abuse prevention, monitoring, capacity planning, quality assurance, further development and protection of our systems.
- Legal bases: Art. 6(1)(f) GDPR; where individual processing operations are directly necessary to provide the contractually owed platform service, additionally Art. 6(1)(b) GDPR.
6.11 Optional analytics, marketing and embedded third-party content
Where we use optional analytics or marketing technologies on the website, social media functions, embedded videos, maps, external font libraries, appointment booking services or comparable third-party content, such content is loaded or activated only if the required consent has been given.
Once such content is activated, your browser may establish a direct connection to the servers of the respective third-party provider. Depending on the provider, the access may be associated with an existing profile if you are logged in there at the same time. We have influence over the subsequent data processing by the respective third-party provider only to the extent resulting from the specific integration of the service.
- Data processed: IP address, browser and device data, page views, interactions, referrer, consent status and cookie-like identifiers.
- Purposes: analytics, campaign evaluation, optimization of the website, integration of external content and improvement of user guidance.
- Legal bases: Art. 6(1)(a) GDPR.
7. Recipients and categories of recipients
We disclose personal data only where this is necessary for the respective processing, legally required or based on an appropriate legal basis. Recipients may include, in particular:
- hosting, infrastructure and CDN service providers
- telecommunications, messaging and integration providers, for example for telephony or WhatsApp Business
- providers of speech processing, AI models, transcription or text-to-speech, insofar as this is necessary for the booked scope of functions
- support, CRM, ticketing, appointment-booking, email and newsletter service providers
- payment service providers, banks, accountants and tax advisors
- analytics, monitoring and security service providers
- debt collection, legal advisory and other service providers for the enforcement or defense of receivables and legal claims
- courts, authorities or other bodies where we are legally obliged to do so or need to assert or defend legitimate claims
Where we use external service providers, we select them carefully, restrict data access to what is necessary and, where required, enter into data processing agreements with them. Personal data is not sold and is not disclosed for independent third-party advertising purposes.
The processors currently used or used depending on the booked function may include in particular:
- Eleven Labs Inc., 169 Madison Ave #2484, New York, NY 10016, United States
- Deepgram, Inc., 548 Market St, Suite 25104, San Francisco, CA 94104-5401, United States
- OpenAI, L.L.C., 3180 18th St, San Francisco, CA 94110, United States
- Microsoft Ireland Operations Limited, One Microsoft Place, D18 P521 Dublin, Ireland
- AWS Amazon - A100 ROW GmbH, Deutschland
- Cal.com Inc., San Francisco Bay Area, West Coast, USA
- TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland
- Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, D04 X2K5, Ireland
- LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland
- Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA
- Google Irland Limited, Gordon House, Barrow Street, Dublin 4, Irland
- Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland
8. Third-country transfers
Some of our service providers or integrations may process data outside the EU or EEA, in particular where customers integrate international telephony, messaging, AI or cloud services.
Where an adequacy decision of the European Commission exists for a third country, we rely on that decision for transfers. Depending on the service provider used, this may apply, for example, to the United Kingdom or to US companies certified under the EU-US Data Privacy Framework.
If no adequacy decision exists, we use appropriate safeguards, in particular standard contractual clauses approved by the European Commission, and implement additional protective measures where necessary. Further information on the safeguards relevant in each case is available upon request, provided that no confidentiality interests prevent this.
9. Retention period
We store personal data only for as long as necessary for the respective purpose. The following criteria are particularly relevant:
- website and security logs: generally only for short periods as required for operation, stability and incident analysis
- cookie, consent and preference data: until the purpose no longer applies, the relevant storage expires, or your selection is changed
- contact, demo and sales data: until the request has been fully handled and beyond that only insofar as follow-up communication, pre-contractual activity or statutory retention obligations require this
- account, contract and platform data: for the duration of the contractual relationship and thereafter until statutory retention and limitation periods expire
- billing and payment data: in accordance with commercial and tax retention obligations
- support, error analysis and security data: as long as necessary for handling, documenting and defending against disruptions or claims
- communication content within the platform: according to the instructions of the respective customer, the contractual settings and technically necessary retention periods; afterwards the data is deleted or anonymized unless statutory obligations prevent this
Backups are overwritten or deleted with a time delay.
10. Obligation to provide data
Providing personal data merely for visiting our website is generally voluntary. However, without certain technical data the website cannot be delivered or protected against attacks.
For registrations, contracts, support, billing and the use of VoiceBots, chatbots or WhatsApp Business functions, we require certain information. If this information is not provided, we may be unable to provide the requested service in whole or in part.
Where processing is based solely on your consent, providing the relevant data is voluntary. Without this consent, certain optional functions, third-party content, marketing measures or communication channels may be unavailable in whole or in part.
11. Your rights
Subject to the applicable legal requirements, you have the right to:
- access to the personal data we process
- rectification of inaccurate data or completion of incomplete data
- erasure, provided no statutory or other legitimate reasons prevent this
- restriction of processing
- data portability, where the relevant requirements are met
- object to processing based on legitimate interests
- withdraw consent with effect for the future
You may object to direct marketing at any time.
If you withdraw consent, the lawfulness of the processing carried out before the withdrawal remains unaffected.
You also have the right to lodge a complaint with a data protection supervisory authority. In particular, the competent authority may be the supervisory authority at your habitual residence, place of work or the place of the alleged infringement.
To exercise your rights, simply send a message to privacy@claiverly.de
. If we process data exclusively on behalf of a customer, we will forward your request to the responsible customer or support the customer in handling it.
12. No solely automated decisions within the meaning of Art. 22 GDPR
Where we act as controller ourselves, we do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you, unless we inform you of this separately and there is a valid legal basis or your explicit consent.
The use of AI-supported VoiceBots, VoiceAgents or chatbots does not automatically mean that a decision within the meaning of Art. 22 GDPR is being made. If customers set up such processes, they are generally responsible themselves for the relevant data protection assessment and the required notices.
13. Data security
We implement appropriate technical and organizational measures to protect personal data against loss, misuse, unauthorized access and unlawful disclosure. Depending on the risk, these measures include, in particular, access restrictions, pseudonymization, encryption during transmission and storage, role-based permissions, logging, backups, and recovery and security review procedures.
14. Changes to this privacy policy
We may amend this privacy policy if legal, technical or business conditions change. The version published at the relevant time shall apply.
As of: March 31, 2026