Privacy Policy

1.Introduction

Elevate Tht Ltd ("we", "us", "our") operates the CallTrackingSoftware platform, accessible at https://calltrackingsoftware.ai (the "Service"). This Privacy Policy explains how we collect, use, store, and protect information when you use our Service.

By accessing or using the Service, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use the Service.

2.Who We Are

The data controller for the Service is:

3.Key Definitions

For the purposes of this policy:

4.Information We Collect

4.1 Account and Registration Data

When an Agency registers for the Service, we collect:

• Full name and job title
• Business email address
• Company name and website
• Billing information (processed by Stripe — we do not store full card details)
• Account credentials (password stored in hashed form)

4.2 Call and Campaign Data

As part of operating the call tracking Service, we collect and process:

• Dedicated tracking phone numbers assigned to campaigns
• Inbound and outbound call logs (date, time, duration, caller ID, called number)
• Call recordings and, where applicable, transcripts
• Campaign attribution data (source, medium, keyword, ad group, landing page)
• Caller geographic data (country, region, approximate location derived from phone number)
• Device type and browser data from Dynamic Number Insertion (DNI) scripts

4.3 Usage and Analytics Data

We collect information about how the Service is used, including:

• Pages visited within the platform and features accessed
• Session duration and interaction events
• IP address, browser type, operating system, and device identifiers
• Referral source and entry page

This data is collected via Google Analytics and PostHog, both of which process data on our behalf under data processing agreements.

4.4 Marketing Attribution Data (Our Own Site)

We use LeadSources.io to track the marketing channel that brought visitors to https://calltrackingsoftware.ai. This data (e.g. organic search, paid ads, referral) is associated with signup records to help us understand which channels drive new Agency registrations. This tool operates only on our own website and is not embedded in Agency or Agency Client campaigns.

4.5 Communications Data

If you contact us by email or through the platform, we retain the content of that communication and your contact details for support and record-keeping purposes.

5.How We Use Your Information

We use collected information for the following purposes:

• To provide, operate, and maintain the Service
• To process payments and manage billing through Stripe
• To provision phone numbers and route calls through Twilio
• To generate call analytics, attribution reports, and campaign dashboards
• To send transactional communications (account confirmations, invoices, service notifications)
• To respond to support requests and enquiries
• To monitor and improve platform performance, reliability, and security
• To detect and prevent fraud, abuse, or violations of our Terms of Service
• To analyse how our own website and marketing channels perform (via Google Analytics, PostHog, LeadSources.io)

6.Legal Basis for Processing

We process personal data on the following legal bases:

• Contract performance: Processing necessary to deliver the Service to Agencies and fulfil our contractual obligations.
• Legitimate interests: Analytics, fraud prevention, security monitoring, and service improvement, where these interests are not overridden by individual rights.
• Legal obligation: Where processing is required to comply with applicable law.
• Consent: Where we explicitly request consent (e.g. marketing communications), you may withdraw it at any time.

7.Third-Party Data Processors

We share data with the following third-party processors, each bound by data processing agreements and required to handle data only on our documented instructions:

8.White-Label Arrangements and Agency Responsibility

CallTrackingSoftware operates as a white-label platform. Agencies deploy the Service to their own clients under their own branding. In this arrangement:

• Elevate Tht Ltd acts as a data processor on behalf of the Agency with respect to Agency Client data collected through the platform.
• The Agency acts as the data controller for its clients' data and is responsible for providing appropriate privacy notices to its own clients, including disclosures about call recording where legally required.
• Elevate Tht Ltd does not have a direct relationship with Agency Clients and does not communicate with them directly.
• Agencies are required to enter into a Data Processing Agreement (DPA) with us before processing personal data of their clients through the Service.

9.Call Recording and Caller Data

The Service records telephone calls as part of its core functionality. Call recording may be subject to legal requirements in the jurisdictions where calls are made or received, including requirements to inform callers that a call is being recorded.

It is the sole responsibility of the Agency to ensure that appropriate caller consent notices and disclosures are in place before recording calls. This includes compliance with applicable telecommunications laws in each jurisdiction where the Agency operates.

Elevate Tht Ltd does not provide legal advice on recording consent requirements and accepts no liability for an Agency's failure to comply with applicable recording laws.

10.Data Retention

• Account data and Platform Data are retained for the duration of the Agency's active subscription.
• Call recordings and Caller Data are retained for as long as the Agency account remains open.
• Upon account cancellation or deletion, all data associated with that account — including call recordings, call logs, campaign data, and account details — is permanently deleted within 90 days.
• Data cannot be selectively deleted on a per-recording or per-call basis while an account is active.
• Financial and billing records may be retained for longer periods where required by applicable law (e.g. tax and accounting obligations under Cyprus law).

11.Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• Encryption of data in transit using TLS
• Encrypted storage of sensitive data at rest
• Access controls limiting data access to authorised personnel
• Regular security assessments and monitoring

No method of transmission over the internet or electronic storage is 100% secure. While we take data security seriously, we cannot guarantee absolute security.

12.International Data Transfers

Our third-party processors, including Twilio, Google, and Stripe, may process data in countries outside Cyprus and the European Economic Area. Where data is transferred internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, or equivalent mechanisms.

13.Your Rights

Depending on your location and applicable law, you may have the following rights with respect to your personal data:

To exercise any of these rights, please contact us at contact@calltrackingsoftware.ai. We will respond within 30 days. Note that some rights may be limited by our legal obligations or the nature of the Service (for example, call recordings cannot be individually deleted while an account is active — see Section 10).

14.Cookies

We use cookies and similar tracking technologies on our website. Our Cookie Policy, available separately, provides full details of the cookies we set, their purpose, and how to manage your preferences.

In summary, we use:

• Strictly necessary cookies: Required for the Service to function (session management, authentication).
• Analytics cookies: Google Analytics and PostHog to understand how visitors use our site.
• Marketing attribution cookies: LeadSources.io to track the marketing source of signups.

15.Children's Privacy

The Service is intended for use by individuals aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that a person under 18 has provided us with personal data, we will delete it promptly.

16.Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the effective date at the top of this document and, where changes are material, notify registered Agencies by email or via an in-platform notice.

Continued use of the Service after any changes constitutes acceptance of the updated policy.

17.Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We aim to respond to all privacy-related enquiries within 30 days of receipt.