1. Introduction

StreamSync Limited ("StreamSync", "we", "our", "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose and safeguard your personal data when you visit www.streamsync.ie, contact us by telephone, or use our services.

We comply with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Data Protection Act 2018.

2. Data Controller

3. When We Are the Controller, and When We Are Not

This policy covers personal data for which StreamSync is the data controller — that is, data about people who visit our website, contact us, call us, or become our customers.

Where we set up and operate call answering, messaging or customer management systems on behalf of a business client, that client is the data controller for their own customers' personal data, and StreamSync acts as a data processor on their written instructions under a data processing agreement. If you are a customer of one of our clients and want to know how your data is handled, please contact that business directly. We will assist them in responding to any request.

4. Personal Data We Collect

4.1 Information you provide

• Name and job title.
• Email address and phone number.
• Business or company name.
• Information you submit via our contact or enquiry forms, or our online readiness scorecard.
• Information you give during a telephone call with us, including with our AI assistant (see Section 5).
• Account and billing details if you become a customer.
• Any other information you choose to provide in correspondence with us.

4.2 Information collected when you call us

• Your telephone number, and the date, time and duration of the call.
• An audio recording of the call, where recording is in use.
• A written transcript of the call.
• A summary of the call and any details you provide, such as your name, address or the reason for calling.

4.3 Information collected automatically

• IP address.
• Browser type and version.
• Device information.
• Website usage data, via cookies and analytics tools (see Section 9).

5. Our AI Voice Assistant

5.1 You are always told

When you telephone StreamSync, your call may be answered by an artificial intelligence assistant rather than a person. The assistant tells you this at the start of every call. We do this because we believe you are entitled to know, and because transparency of this kind is required under Article 50 of the EU Artificial Intelligence Act (Regulation (EU) 2024/1689).

5.2 What it does

The assistant answers your call, helps with questions about our services, takes your contact details, and can book an appointment or take a message. It does not make decisions about you, and it does not produce any legal or similarly significant effect. A person reviews the details captured and follows up with you.

5.3 What is processed, and by whom

To operate the assistant, the audio of your call is converted to text, processed by a large language model to generate a response, and converted back into speech. This involves third-party artificial intelligence, speech recognition and speech synthesis providers acting as our processors, some of which are located outside the European Economic Area. See Sections 7 and 8.

5.4 If you would prefer a person

You can ask at any point during the call to speak to a person, or you can email us at [email protected] instead. You will not receive a worse service for doing so.

5.5 Accuracy

Automated speech recognition is not perfect, particularly with names and place names. The assistant will read details back to you for confirmation. If something has been recorded incorrectly, you can ask us to correct it at any time (see Section 12).

6. How We Use Your Data

• To respond to your enquiries, including calls answered by our AI assistant.
• To provide, manage and support our services.
• To process payments and maintain financial records.
• To keep an accurate record of what was agreed during a call.
• To check the quality and accuracy of our AI assistant and correct errors in how it handles calls.
• To improve our website performance and user experience.
• For analytics and business insights.
• For marketing communications, where permitted (see Section 7 and your right to object in Section 12).

We do not use recordings or transcripts of your calls to train third-party artificial intelligence models.

7. Legal Basis for Processing

• Consent — for example, non-essential cookies and marketing communications. Where call recording relies on consent, you are told at the start of the call and may decline by ending the call and contacting us by email instead.
• Contract — where processing is necessary to provide our services to you, or to take steps at your request before entering a contract.
• Legitimate interests — to respond to enquiries, to answer calls we would otherwise miss, to keep an accurate record of what was discussed, and to improve our services and website, balanced against your rights.
• Legal obligation — where we are required to retain records by law.

8. Who We Share Your Data With

We share personal data only where necessary, with providers acting on our instructions under data processing agreements:

• HighLevel Inc. / LeadConnector — our CRM, automation, telephony and website platform, including the AI voice assistant.
• Twilio — telephony and messaging.
• Artificial intelligence providers — the language model, speech recognition and speech synthesis services that operate our AI assistant, provided through the HighLevel platform. A current list of these providers is available on request by emailing [email protected].
• Stripe — payment processing.
• Mailgun — email delivery.
• Google Analytics — website analytics (where enabled, with consent).
• Our accountants and professional advisors — for bookkeeping, legal and financial matters.

All third parties are required to process personal data in compliance with GDPR. We do not sell your personal data.

9. International Data Transfers

Some of our providers are based outside the European Economic Area (EEA), primarily in the United States. This includes the artificial intelligence and speech processing services used by our voice assistant, which means that audio and transcripts of calls may be processed outside the EEA. Where personal data is transferred outside the EEA, we ensure an appropriate safeguard is in place, namely:

• the EU-US Data Privacy Framework, where the provider is certified under it; or
• Standard Contractual Clauses approved by the European Commission, where the Data Privacy Framework does not apply.

10. Cookies

10.1 What cookies are

Cookies are small files stored on your device when you visit a website.

10.2 Types of cookies we use

• Strictly necessary — required for the website to function.
• Analytics — to understand how the site is used.
• Marketing — for advertising purposes.

10.3 Consent

We only use non-essential cookies with your prior consent, as required under Irish ePrivacy rules. You can manage your preferences through our cookie banner at any time. A full list of cookies is set out in our Cookie Policy.

11. Data Retention

We retain personal data only as long as necessary to fulfil the purposes set out in this policy and to comply with our legal obligations. When data is no longer required, it is securely deleted.

• Enquiries — 12 months from last contact.
• Call recordings — 12 months from the date of the call, unless the call relates to a contract or dispute, in which case it is retained for as long as needed for that purpose.
• Call transcripts and summaries — retained with the associated enquiry or customer record.
• Customer and financial records — the contract duration plus six years, as required by Irish tax law.

12. Your Rights

Under GDPR you have the right to: access your data; have inaccurate data corrected; have your data erased; restrict processing; data portability; and object to processing, including direct marketing.

Your right of access includes any recording, transcript or summary we hold of a call with you. Please tell us the approximate date and time of the call so that we can locate it.

We will respond to your request within one calendar month. This may be extended by up to two further months for complex requests, in which case we will let you know within the first month.

You also have the right to lodge a complaint with the Irish Data Protection Commission (www.dataprotection.ie).

13. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including secure hosted infrastructure, HTTPS, access controls, and encryption where appropriate. Access to call recordings and transcripts is restricted to those who need it.

14. Data Breaches

In the event of a personal data breach, we will notify the Data Protection Commission where required within 72 hours, and we will inform affected individuals where there is a high risk to their rights and freedoms.

15. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites.

16. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date.

17. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact us: