1. Controller
The operator of Piketto named above (“we”) is the controller responsible for the processing described in this policy. Please send data protection enquiries to the email address provided.
2. Our role: controller and processor
We are the controller within the meaning of the FADP for our customers’ data (account, contract and billing) and for visits to our website.
When our phone assistant answers calls for a business, we process callers’ data on behalf of that business. In this case, the business concerned is the controller; we act as a processor under Art. 9 FADP in accordance with our Data processing agreement. Callers can therefore also find information about the processing of their data in the privacy policy of the business they call and can exercise their rights directly with that business. We assist the business in doing so.
3. The data we process
Customers (businesses and their users):
- Account data: name, email address, password (stored only as a cryptographic hash), preferred language and role within the account.
- Business details for the phone assistant: company name, sector, address, opening hours, services, frequently asked questions, call transfer and notification numbers, and notification email address.
- Contract and billing data: billing address, VAT number, subscription status and invoices. Payment method details are collected exclusively by our payment provider; we do not receive full card numbers.
- Usage data: number and duration of calls for billing purposes, and technical logs for service security.
Callers to businesses that use our service:
- Caller number (Caller ID), where transmitted, and the time and duration of the call.
- Voice: speech is processed in real time during the call so that it can be understood and answered. No audio recordings are stored.
- Transcript of the call (text).
- Information captured during the call: name, confirmed callback number, reason for calling, urgency, appointment request and a summary.
- Content that callers provide of their own accord. We ask businesses to configure their phone assistant so that it does not request sensitive personal data.
Website visitors:
- Technically necessary server logs (IP address, time, page accessed and browser type) to deliver and secure the website.
4. Purposes of processing
- Providing the service: answering calls, answering questions using the business’s information, capturing callers’ requests and transferring urgent calls.
- Notifying the business by email and SMS and displaying information in the dashboard.
- Performing the contract, billing based on call duration and accounting.
- Customer support and communications relating to the contract.
- Security, prevention of misuse and fraud, and error analysis.
- Compliance with legal obligations, such as retention requirements.
We do not use callers’ data for advertising, sell personal data or use call content to train our own AI models.
The grounds for processing include, in particular, performance of the contract, our legitimate interests in a secure and functioning service, and legal obligations; where the GDPR applies, Art. 6 para. 1 lets. b, c and f GDPR.
5. Recipients and subprocessors
We use carefully selected service providers that process personal data on our behalf and in accordance with our instructions. They are contractually bound to maintain confidentiality and data security.
| Provider | Purpose | Processing location | Safeguards |
|---|---|---|---|
| ElevenLabs (including its language-model subprocessors) | Voice AI: speech recognition, conversation handling with Google Gemini, speech output and summaries | USA; other countries are possible according to ElevenLabs’ subprocessor list | Data processing agreement; Swiss-U.S. Data Privacy Framework where certified, otherwise standard contractual clauses recognised by the FDPIC and adapted for Switzerland |
| netcup GmbH | Hosting the application and PostgreSQL database on a virtual server | Vienna, Austria (EU) | Data processing agreement; adequate data protection in Austria |
| Cloudflare | CDN, TLS and DDoS protection | Global network; provider based in the USA | Data processing agreement; Swiss-U.S. Data Privacy Framework; for other countries, standard contractual clauses under section 6 where needed |
| Google Workspace (Google) | Email for [email protected] and transactional email delivery through an SMTP relay | USA and EU | Data processing agreement; Swiss-U.S. Data Privacy Framework |
| Twilio | Telephony (Swiss telephone numbers, call forwarding and call transfers) and SMS delivery | USA and EU | Data processing agreement; Swiss-U.S. Data Privacy Framework and standard contractual clauses under section 6 |
| Stripe | Payment processing, subscriptions and invoices (customer data only, no call data) | USA and EU | Data processing agreement; Swiss-U.S. Data Privacy Framework and standard contractual clauses under section 6 |
| Foci SA (own infrastructure) | Encrypted database backup copy; no additional subprocessor | Switzerland | Encryption and restricted access; no international transfer for this backup copy |
We use ElevenLabs’ standard platform through api.elevenlabs.io. ElevenLabs processes call data in the USA and potentially in other countries under its data processing agreement. Google Gemini is used through ElevenLabs to handle conversations; language-model providers are subprocessors of ElevenLabs, not separate providers engaged directly by us. Audio recording storage is disabled at ElevenLabs for our customers’ accounts; call data held there is deleted within 30 days at the latest.
Data may also be disclosed to authorities where we are legally obliged to do so.
6. Disclosure abroad
The application and database are hosted by netcup in Vienna, Austria; an encrypted backup copy is held on our own infrastructure in Switzerland. ElevenLabs, Cloudflare, Google Workspace, Twilio and Stripe also process data outside Switzerland and the EU, particularly in the USA. International transfers take place only under the conditions set out in Art. 16 and 17 FADP:
- to countries with an adequate level of data protection according to the Federal Council, in particular EU and EEA countries;
- to the USA on the basis of the Swiss-U.S. Data Privacy Framework where the recipient is certified for the processing concerned; otherwise, and for processing in other countries without adequate data protection, on the basis of the European Commission’s standard contractual clauses recognised by the FDPIC, with the adaptations required for Switzerland and supplementary safeguards where necessary.
On request, we will provide information about the safeguard used in each case.
7. Retention and deletion
- Audio recordings: no audio recordings of calls are stored. Call data held by our voice AI provider ElevenLabs is deleted within 30 days at the latest.
- Transcripts and captured caller information: for the period the business specifies in its settings — between 7 and 365 days, with a default of 90 days. They are then automatically deleted. Businesses can delete individual calls earlier at any time.
- After this period expires, we retain only the time and duration of a call, without its content or caller information, to the extent needed for billing and evidentiary purposes.
- Deletion by the business: the account owner can delete the account at any time in Settings. The business profile, call records and transcripts are then deleted immediately, the phone assistant is removed from the voice AI provider, the Swiss number is released and any subscription is cancelled immediately.
- End of contract: when a subscription ends (cancelled or expired), we delete all customer data 30 days after the end of the last billing period.
- Accounts without a subscription: if a subscription was never started, we delete the account and all its data 60 days after sign-up.
- Account data: until the account is deleted under the rules above. We retain accounting records and accounting vouchers for ten years in accordance with Art. 958f of the Swiss Code of Obligations (CO).
- Server logs: generally no longer than 30 days, unless needed to investigate a security incident.
8. Data security
We take appropriate technical and organisational measures under Art. 8 FADP, in particular: encrypted transmission (TLS), strict separation of data belonging to different businesses, access restricted to authorised persons on a need-to-know basis, passwords stored exclusively as hashes, data minimisation through the absence of audio recordings and automatic deletion periods, and regular review of the service providers used.
9. Your rights
Under applicable data protection law, you have the following rights in particular:
- access to information about the data processed about you (Art. 25 FADP);
- rectification of inaccurate data (Art. 32 FADP);
- erasure or restriction of processing, and objection to processing;
- delivery or transfer of your data in a commonly used electronic format (Art. 28 FADP);
- withdrawal of consent with effect for the future.
To make a request, simply email the address given in section 1. We may require proof of identity. Callers should preferably send their request to the business they called; if we receive it directly, we will forward it and assist the business in responding.
10. Complaints to the FDPIC
You have the right to lodge a complaint with the supervisory authority: Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, www.edoeb.admin.ch. Where the GDPR applies, you may also contact a supervisory authority in the EU.
12. Artificial intelligence and automated decisions
Our phone assistant is an artificial intelligence system and identifies itself as such at the start of every call. It does not make automated individual decisions within the meaning of Art. 21 FADP: appointment and callback requests are captured and then handled and confirmed by the business.
13. Changes
We may amend this Privacy policy if our service or the legal position changes. The version published on this page applies. We will notify our customers of material changes by email.