Privacy Policy

This Privacy Policy explains how Initrel (a NiNow company) collects, uses, discloses, and safeguards information in connection with our voice-powered onboarding products and related services (the “Services”). We design with privacy by default; we collect only what is necessary, and we never sell personal data.

Scope & Definitions

This Policy applies to information processed about customers, end users, website visitors, and prospective customers. “Personal Data” means any information that identifies or relates to an identified or identifiable individual. “Customer Data” means data submitted to the Services by or on behalf of a customer.

Controller/Processor Roles

For Personal Data we collect through our marketing site or direct interactions, Initrel is the data controller. For Customer Data processed within the Services, Initrel acts as a processor/service provider to our customers (the controllers), processing such data pursuant to our contracts, Data Processing Addendum (DPA), and, where applicable, Business Associate Agreement (BAA) for HIPAA-covered entities and business associates.

Information We Collect

• Account & Contact Data: name, email, organization, and role.
• Usage Data: device/browser information, IP address, timestamps, pages or features used.
• Voice/Conversation Data: audio streams, transcripts, prompts, and conversation metadata processed to deliver the Services.
• Support Data: information you provide in tickets, surveys, or feedback.
• Third-Party Sources: integrations or partners you authorize (e.g., CRMs, storage).

Legal Bases (EEA/UK/Similar)

• Performance of a contract (providing and operating the Services).
• Legitimate interests (security, analytics, product improvement, preventing abuse).
• Consent (where required, e.g., certain cookies or marketing communications).
• Compliance with legal obligations.

How We Use Information

• Provide, configure, and maintain the Services (including voice processing and transcripts).
• Secure the Services, prevent abuse, and investigate incidents.
• Improve and develop new features, models, and user experiences.
• Provide support and respond to inquiries.
• Comply with law and enforce agreements.

Disclosure & Subprocessors

We disclose Personal Data to trusted service providers (subprocessors) under written agreements requiring confidentiality, security, and data protection obligations. We may disclose information as required by law, in connection with a merger or acquisition, or to protect rights, privacy, safety, or property. We maintain a current list of subprocessors upon request and via our TrustShare page.

International Transfers

When transferring Personal Data internationally, we implement appropriate safeguards, such as Standard Contractual Clauses and additional security controls. For HIPAA data, we follow contractual and legal requirements regarding data location and access.

Security

We employ administrative, technical, and physical safeguards, including encryption in transit and at rest, access controls, audit logging, vulnerability management, and incident response processes. See our Security page for details.

Data Retention

We retain Personal Data only as long as necessary for the purposes described, to comply with legal obligations, resolve disputes, and enforce agreements. Customers can configure retention for Customer Data, subject to applicable law and our contractual commitments.

Your Rights

Subject to applicable law, you may have rights to access, correct, delete, or port Personal Data, and to object to or restrict certain processing. When we process Customer Data as a processor, we will direct requests to the relevant customer controller. To exercise rights, contact us at the email below.

Children

Our Services are not directed to children under 13 (or other age as defined by local law), and we do not knowingly collect Personal Data from children without appropriate consent.

Changes to this Policy

We may update this Policy from time to time. We will notify you of material changes as required by law. The “Last updated” date will reflect the most recent changes.

Contact

Questions or requests: hello@initrel.com.