Privacy Policy

Last Updated: August 20, 2026

Data Controller: Lokutor AI, registered in Spain.

Data Protection Officer: privacy@lokutor.com

This Privacy Policy explains how we collect, use, share, and protect personal data when you use the Lokutor platform, APIs, and services ("Services"). We comply with the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable data protection laws.

1. What We Collect

1.1 Account Data

When you register, we collect: name, email address, company name, role, and payment information (processed by Stripe).

1.2 Voice and Audio Data

Voice data you submit for processing (e.g., text-to-speech input, speech-to-text audio, voice agent conversations) is processed to deliver the requested Services. This may include your voice recordings, which could constitute biometric data under applicable law (Illinois BIPA, GDPR Art. 9, etc.).

We process voice data only as necessary to deliver the Services you request. We do not use voice data to identify or profile individuals.

Model training. We do not currently train or fine-tune models on customer voice data or conversations. We may do so in future for free-plan conversations, in order to improve agent behaviour. If we do, we will say so here and give at least 30 days’ notice before it begins, and paid plans will remain excluded unless they opt in. We will not begin training on voice data without first establishing the lawful basis that voice data requires, which in the EU is a higher bar than ordinary personal data because voice can constitute biometric data under GDPR Article 9.

Speech APIs (TTS, STT, noise cancellation) process audio in-flight. The audio is not written to disk as a stored recording.

1.3 Conversation Data

Voice Agent conversations, transcripts, and associated metadata may be stored for quality assurance, debugging, and evaluation purposes for up to 90 days, unless you request earlier deletion.

1.4 Call Recording

Recording of Voice Agent call audio is off unless enabled for that Agent. Where recording is enabled:

  • The Agent states at the start of the call that the conversation is recorded, before substantive conversation begins, so that the other party is informed as consent law requires.
  • Recordings are stored encrypted in a non-public bucket and are retrievable only via short-lived signed links issued to authorised people.
  • Recordings follow the same 90-day retention as transcripts, or are deleted sooner on request.

Free plans. On free plans, recording is enabled and cannot be disabled, and Lokutor personnel may listen to recordings to diagnose faults and improve the Services. For this specific purpose Lokutor acts as a controller rather than a processor, relying on legitimate interests (Art. 6(1)(f)) in operating and improving a free tier; the interest is disclosed here and on the call itself, access is restricted to personnel who need it, and the 90-day limit applies. Any paid plan can disable recording entirely, in which case no call audio is written to disk at all. If you would rather no audio were retained, use a paid plan with recording off.

1.4 Usage Data

We collect: API request logs (timestamps, endpoints, status codes, latency), character/minute counts for billing, IP addresses, browser/device information, and general usage analytics.

1.5 Knowledge Documents

Documents and URLs you upload as knowledge base content for Voice Agents are stored and processed to enable retrieval during agent conversations.

2. How We Use Your Data

We process personal data based on the following legal grounds under GDPR Article 6:

PurposeLegal Basis
Providing and operating the Services (TTS, STT, Voice Agents, API)Performance of a contract (Art. 6(1)(b))
Processing voice/audio for real-time STT and TTSPerformance of a contract (Art. 6(1)(b))
Recording calls on free plans, and staff review of those recordings, to operate and improve the free tierLegitimate interests (Art. 6(1)(f)) — disclosed on the call; avoidable by using a paid plan with recording off
Billing, subscription management, payment processingPerformance of a contract (Art. 6(1)(b))
Account management, security, fraud preventionLegitimate interest (Art. 6(1)(f))
Service analytics and improvementLegitimate interest (Art. 6(1)(f))
Legal compliance, regulatory obligationsLegal obligation (Art. 6(1)(c))
Marketing communications (new features, newsletters)Consent (Art. 6(1)(a)) — opt-in only

2.1 Biometric Data

Under GDPR Article 9 and certain US state laws (including Illinois BIPA), voice data may be classified as biometric data. We process biometric voice data solely to deliver the Services (speech recognition and synthesis). We do not create permanent voice profiles or use voice data for identification/authentication purposes. We do not sell biometric data to third parties.

2.2 Telecommunications Compliance

When you use Voice Agent phone features, you are responsible for compliance with applicable telecommunications laws, including:

  • Call recording consent requirements (one-party or all-party consent jurisdictions)
  • AI disclosure requirements where applicable
  • Telemarketing regulations (TCPA, CAN-SPAM, PECR, etc.)
  • Do-not-call registry compliance

3. Data Sharing

We share personal data with the following categories of recipients:

  • Payment Processor: Stripe, Inc. — for subscription billing and payment processing. Stripe Privacy Policy
  • Cloud Infrastructure: Amazon Web Services (AWS) — for hosting, storage, and compute. Data processed in eu-west-1 (Ireland) and eu-west-3 (Paris) regions.
  • Telecom Provider: Telnyx — for phone number provisioning and call routing (for Voice Agent phone features).
  • LLM Providers: Groq, Google Gemini — for AI language model inference. Data is transmitted in real time and not retained by these providers after processing.
  • Analytics: Vercel Analytics — for performance and usage analytics.

We do not sell personal data. We do not share personal data with third parties for their own marketing purposes.

4. International Data Transfers

Our primary data processing occurs within the EU (AWS eu-west-1, Ireland). Certain data may be transferred to the United States for infrastructure management and third-party service providers. We rely on the following transfer mechanisms:

  • EU-U.S. Data Privacy Framework (DPF) certification
  • EU Standard Contractual Clauses (SCCs) with sub-processors
  • Adequacy decisions where applicable

5. Data Retention

Data TypeRetention Period
Account informationDuration of Account + 30 days after deletion
Voice agent conversations & transcripts90 days (unless extended by you)
Call recordings (where recording is enabled)90 days, or sooner on request
API usage logs (for billing)12 months
Knowledge base documentsDuration of the associated Agent + 30 days
Payment records7 years (legal requirement)
Phone number recordsDuration of number ownership + 30 days

6. Your Rights (GDPR)

If you are in the European Economic Area (EEA), United Kingdom, or Switzerland, you have the following rights under GDPR:

  • Right of Access (Art. 15): Request a copy of your personal data.
  • Right to Rectification (Art. 16): Correct inaccurate personal data.
  • Right to Erasure (Art. 17): Request deletion of your personal data ("Right to be Forgotten").
  • Right to Restriction (Art. 18): Request restriction of processing.
  • Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format.
  • Right to Object (Art. 21): Object to processing based on legitimate interests or for direct marketing.
  • Right to Withdraw Consent (Art. 7(3)): Withdraw consent at any time without affecting the lawfulness of prior processing.
  • Right to Lodge a Complaint: File a complaint with your local supervisory authority.

To exercise these rights, email privacy@lokutor.com. We will respond within 30 days.

7. Your Rights (US — CCPA/CPRA/Other States)

If you are a California resident, you have additional rights under the CCPA/CPRA:

  • Right to Know: Request disclosure of the categories and specific pieces of personal information collected, used, and disclosed.
  • Right to Delete: Request deletion of personal information.
  • Right to Opt-Out of Sale: We do not sell personal information.
  • Right to Non-Discrimination: We will not discriminate against you for exercising your rights.

Residents of other US states (Virginia, Colorado, Connecticut, Utah, Oregon, Montana, Texas, Iowa, Nebraska, Delaware) have similar rights. Contact privacy@lokutor.com to exercise them.

8. Security

We implement appropriate technical and organizational measures to protect your personal data, including:

  • Encryption of data in transit (TLS 1.3) and at rest (AES-256)
  • Row-level security on all database tables
  • Role-based access controls for internal systems
  • Regular security audits and vulnerability assessments
  • SOC 2 Type II compliance (in progress)

9. Children's Privacy

The Services are not intended for children under 18. We do not knowingly collect personal data from children. If you believe we have collected such data, contact us immediately at privacy@lokutor.com.

10. Third-Party Links

The Services may contain links to third-party websites or services. We are not responsible for their privacy practices. We encourage you to review their privacy policies.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or in-app notification at least 30 days before taking effect. The "Last Updated" date at the top indicates the latest revision.

12. Contact

Data Protection Officer: privacy@lokutor.com

General Inquiries: support@lokutor.com

Mail: Lokutor AI — Privacy Team
Spain (registered office address to be provided)

13. Sub-Processors

The following third-party sub-processors process data on our behalf:

Sub-ProcessorPurposeData ProcessedLocation
Amazon Web Services (AWS)Cloud hosting & computeAll service dataEU (Ireland, Paris)
Stripe, Inc.Payment processingPayment details, billing infoUSA
TelnyxTelecom servicesPhone numbers, call metadataUSA
GroqLLM inferenceTranscripts (real-time, not stored)USA
Google Cloud (Gemini)LLM inference & evaluationTranscripts (real-time)USA
VercelFrontend hosting & analyticsUsage analytics, HTTP logsUSA

Sub-processors are updated periodically. Current list: https://lokutor.com/legal/sub-processors