Data Processing Agreement

Tinos provides a phone assistant that answers the calls received on your number, informs your callers, books appointments, sends confirmation text messages to your customers and gives you a summary of each conversation. To provide this service, Tinos processes the personal data contained in those calls.

The processing lasts as long as your account is active. It ends when your account is closed, under the terms of article 8.

On your behalf, Tinos processes the following categories of data:

• the caller's phone number, and their name when they give it
• the audio recording of the call, when you have enabled it
• the written transcript of the call and the automatically generated summary
• the purpose of the request, the appointment booked (date, time slot, service)
• the contact details stored in your customer records, including those you import
• the messages exchanged on the written channels you enable

The data subjects are your callers, your customers and prospects, and the members of your team whose contact details appear in your configuration.

Calls are transcribed and stored: information relating to a caller's health may therefore appear in the transcripts, even when audio recording is disabled. Tinos is not certified as a health data host (HDS, the French certification). It is for each customer, in particular healthcare professionals, to assess whether this use is compatible with their own obligations and, where appropriate, to configure the assistant so as to limit the information collected.

Tinos processes your callers' data solely to provide the Service to you, and only on your instructions. Your settings in the dashboard constitute your documented instructions: the guidance given to the assistant, enabling recording, retention periods, notification recipients, call transfers.

If an instruction appears to us to be contrary to the GDPR, we will inform you and may suspend its execution.

Tinos never uses your data or your callers' data to train or improve artificial intelligence models, nor for its own purposes.

The persons authorised to access the data are bound by confidentiality. The security measures actually in place are as follows:

• encryption of data in transit (HTTPS, encrypted protocols with our providers)
• database hosted in the European Union, segregated by customer account
• secrets and access keys kept outside the source code, in our hosting providers' vaults
• automatic masking, before storage, of bank card numbers, IBANs and social security numbers spoken during a call
• automatic deletion of recordings and transcripts at the scheduled date
• daily backups performed by our database host

Tinos is currently certified neither ISO 27001 nor HDS, and has not appointed a data protection officer: such an appointment is not mandatory given our size and our processing activities.

You authorise Tinos to use the following sub-processors, which take part in the processing of calls and of the associated data:

• Supabase — database, storage of transcripts and recordings (European Union)
• LiveKit — real-time transport of the voice during the call (Frankfurt, Germany)
• Deepgram — speech transcription (European Union endpoint)
• OpenAI — language model that formulates the assistant's answers
• Cartesia — synthesis of the assistant's voice
• Twilio — telephony and text message delivery
• Railway — hosting of the voice assistant
• Vercel — hosting of the dashboard
• Resend — delivery of notification emails

Each one is bound to Tinos by protection obligations equivalent to those of this agreement. Stripe (payment) and Cloudflare (bot protection) do not access any of your callers' data and therefore do not appear in this list.

Any change of sub-processor is announced to you at least fifteen days in advance. You may object to it on legitimate data protection grounds; failing an agreement, you may terminate free of charge before the change takes effect.

The data is hosted in the European Union. Some of our sub-processors may nevertheless process data from the United States. These transfers are governed by the Standard Contractual Clauses approved by the European Commission.

Tinos helps you, as far as possible, to respond to requests from your callers exercising their rights (access, rectification, erasure, portability, objection). For this purpose, data export and deletion are available to you from your dashboard. A request addressed directly to Tinos is passed on to you, without being answered on your behalf.

In the event of a personal data breach, Tinos informs you without undue delay and no later than 48 hours after becoming aware of it, with the information needed for your own notification to the CNIL. Tinos also helps you, on request, to carry out a data protection impact assessment where one is required.

When your account is closed, Tinos deletes your callers' data, except where retention is legally required. You may ask for it to be returned before closure: the export is available at any time from your dashboard. In the absence of a request from you, deletion takes place automatically.

The retention periods applicable during the contract are detailed in our privacy policy.

Tinos makes available to you the information needed to demonstrate compliance with its obligations and answers your written questionnaires within a reasonable time. An on-site audit may be carried out once a year, subject to thirty days' notice, during business hours and without disrupting the Service. Its costs are borne by you, unless it reveals a significant failure by Tinos.

Each party is liable for its own breaches of the GDPR. This agreement is governed by French law; disputes fall within the jurisdiction of the courts designated by the Terms of Service.

Any question regarding this agreement may be sent to us via our contact page.