1. Introduction and Scope
1.1 Purpose of This Policy
This Privacy Policy describes how True Pay 4 Performance Inc., operating as Truedy AI
(“Truedy AI,” “we,” “our,” or “us”), collects, uses, discloses, retains, and protects personal
information when you visit our website, create an account, subscribe to and use the Truedy AI
platform, access our API, or interact with our GoHighLevel Marketplace integration (collectively,
the “Services”).
We take our obligations under applicable data protection laws seriously. This Policy is designed
to give you full transparency about our data practices so that you can make informed decisions
about your privacy.
1.2 Scope of Application
This Privacy Policy applies to:
(a) Customers: Businesses and individuals who subscribe to and use the Truedy AI platform.
(b) Authorized Users: Employees, contractors, and representatives of Customers who access
the Services under a Customer’s Account.
(c) Contact Subjects: Individuals whose personal information (such as phone numbers) is
uploaded to the platform by Customers for use in call campaigns or workflows. These
individuals are data subjects whose information is processed by Truedy AI on behalf of the
Customer.
(d) Call Recipients: Individuals who receive or place telephone calls facilitated through the
Services.
(e) Website Visitors: Anyone who visits the Truedy AI website or documentation portal without
having a paid Account.
1.3 Customers as Data Controllers
When Customers upload contact data, configure call campaigns, and direct the AI agents
deployed through our Services, the Customer is acting as a data controller and Truedy AI is
acting as a data processor with respect to that data. Truedy AI will process Contact Subject
data only on behalf of and at the direction of the Customer. Customers are responsible for
ensuring they have a lawful basis for providing contact data to Truedy AI and for directing us to
contact individuals on their behalf.
1.4 Truedy AI as Data Controller
With respect to data Truedy AI collects directly about Customers and Authorized Users (such as
account information, billing data, and usage analytics), Truedy AI acts as a data controller.
2. Who We Are
True Pay 4 Performance Inc. (also known as True P4P®) is a corporation headquartered in
Newport Beach, California, United States. We operate the Truedy AI platform, a voice AI service
that enables businesses to deploy and manage AI-powered telephone agents for outbound and
inbound call automation.
For data protection inquiries or to exercise your privacy rights, contact us at:
Phone: (833) 838-7747
Email:
privacy@truedy.ai
General Inquiries:
Mailing Address:
info@truep4p.com
True Pay 4 Performance Inc.
Attn: Privacy Officer
Newport Beach, California
United States
3. Definitions
“Aggregate Data” means data compiled from multiple individuals or accounts in a form that
does not identify any specific individual or Customer.
“Authorized User” means any individual authorized by a Customer to access and use the
Services on the Customer’s behalf.
“Biometric Identifier” means a physiological characteristic used to identify a person, including
voiceprints or voice-based biometric data, as defined under applicable state and federal laws.
“Call Data” means all data generated from a voice interaction conducted through the Services,
including recordings, transcripts, call duration, call outcome, sentiment analysis, summaries,
and metadata.
“Contact Subject” means an individual whose personal information (such as name or phone
number) has been uploaded to the Services by a Customer for purposes of outbound calling or
contact management.
“Customer” means a business or individual that has a paid subscription to use the Services.
“Personal Data” means any information that relates to an identified or identifiable natural
person, as defined by applicable data protection law.
“Processing” means any operation performed on Personal Data, whether or not by automated
means, including collection, recording, organization, structuring, storage, adaptation, retrieval,
consultation, use, disclosure, dissemination, combination, restriction, erasure, or destruction.
“Sensitive Personal Data” means a category of Personal Data that receives heightened
protection under applicable law, including information about racial or ethnic origin, political
opinions, religious beliefs, health, biometric data, and financial account details.
“Services” means all products, features, APIs, and integrations offered by Truedy AI.
“Third-Party Services” means external platforms and services that integrate with Truedy AI,
including GoHighLevel, Ultravox, ElevenLabs, Telnyx, Stripe, and Clerk.
4. Information We Collect
4.1 Information You Provide to Us Directly
(a) Account Registration Information
When you create a Truedy AI account, we collect:
Full name or business name
Email address
Password (stored in hashed form, never in plain text)
Company name, size, and industry (optional)
Job title or role (optional)
Phone number for account verification or support purposes
(b) Billing and Payment Information
When you subscribe to a paid plan, billing information is collected by our payment processor
(Stripe). We do not store full credit card numbers on our own servers. We do receive and store:
The last four digits of your payment card
Card type and expiry date (via Stripe)
Billing name and billing address
Stripe customer identifier
(c) Agent Configuration and Content
When you create and configure AI voice agents, we collect:
Agent name, persona settings, and voice preferences
Greeting scripts, conversation prompts, and objection handling instructions
Call disposition categories and outcome definitions
Phone numbers assigned to agents
Integration settings and custom workflow logic
(d) Contact Data Uploaded by Customers
Customers may upload contact lists for outbound calling campaigns. Such contact data may
include:
Full names of contacts
Phone numbers (mobile, landline, or business)
Email addresses
Company names and job titles
Custom fields defined by the Customer
GoHighLevel contact identifiers and CRM data
Truedy AI processes this contact data solely on behalf of and at the direction of the Customer
as a data processor.
(e) Communications with Truedy AI
When you contact our support team, send us emails, or participate in surveys or feedback
forms, we collect the content of those communications along with your contact information and
any supporting documentation you provide.
4.2 Information Collected Automatically
(a) Usage and Activity Data
When you use the Services, we automatically collect:
Pages and features accessed, and time spent on each
Actions taken within the platform (such as creating campaigns, modifying agents, or
reviewing analytics)
API requests made, including endpoints accessed, timestamps, and response codes
Error logs and crash reports
Preferences and settings configurations
(b) Device and Technical Data
We collect technical information about the devices and browsers used to access the Services,
including:
IP address (which may be used to infer approximate geographic location)
Browser type and version
Operating system and device type
Screen resolution
Referring URL and exit URL
Language preferences
Time zone settings
(c) Call Metadata
For every call placed or received through the Services, we collect metadata including:
Call direction (inbound or outbound)
Calling number and called number
Call start time, end time, and duration in seconds
Call outcome classification (e.g., contacted, voicemail, no answer, busy)
Telephony provider call identifier
Geographic region of the call (country or area code level)
(d) Cookies and Similar Technologies
We use cookies and similar tracking technologies as described in Section 12.
4.3 Call Recordings and AI-Processed Data
If you enable call recording, we collect and store audio recordings of calls. We also generate,
through automated AI processing, the following derived data from calls:
Machine-generated transcripts of the call audio
Sentiment analysis scores (positive, neutral, or negative)
Call outcome classifications based on transcript and metadata analysis
Short summaries and key moment extractions from the call
The collection and processing of call recordings is subject to the requirements set out in Section
8. Customers are solely responsible for obtaining required consent from call participants before
enabling recording.
4.4 Information from Third-Party Integrations
(a) GoHighLevel
When you connect your GoHighLevel account to Truedy AI, we receive:
OAuth access tokens and refresh tokens authorizing us to act on your behalf
Your GoHighLevel location (sub-account) identifier
Contact data retrieved from GoHighLevel for call campaigns (name, phone number, custom
fields)
Workflow trigger event details as configured by you
(b) Telephony Provider (Telnyx)
We receive telephony metadata and call detail records from Telnyx, including:
Call status and disposition records
Error codes and failure reasons
Carrier routing information
(c) Payment Processor (Stripe)
We receive from Stripe:
Payment status and confirmation identifiers
Customer billing profile data
Subscription lifecycle events (e.g., trial started, payment failed, subscription cancelled)
(d) Authentication Provider (Clerk)
We use Clerk for identity management. Through Clerk we receive:
User identity data including verified email addresses
Organization identifiers and membership details
Authentication event logs
4.5 Information We Do Not Collect
We do not intentionally collect:
Government-issued identification numbers (e.g., Social Security Numbers or passport
numbers) except where required by law
Sensitive Personal Data such as health, financial account, or standalone biometric
identifiers, except to the extent incidentally present in call recordings or transcripts (which
are processed by Customers at their own direction and subject to Section 9)
Information from individuals under the age of 18
5. How We Use Your Information
5.1 Providing and Maintaining the Services
We use your information to:
(a) create and manage your Account;
(b) process and fulfill your Subscription;
(c) deploy, operate, and maintain AI voice agents as configured by you;
(d) execute outbound and receive inbound calls on your behalf;
(e) generate and deliver call analytics, transcripts, sentiment scores, and summaries;
(f) provide API access and process API requests;
(g) operate the GoHighLevel integration and fire workflow triggers; and
(h) store and make available call recordings, transcripts, and campaign history.
5.2 Billing and Payments
We use billing information to:
(a) process Subscription payments and usage-based charges;
(b) issue invoices and receipts;
(c) manage failed payment recovery and dunning processes; and
(d) issue refunds where applicable.
5.3 Customer Support and Communications
We use your information to:
(a) respond to support requests, bug reports, and inquiries;
(b) send transactional communications, including onboarding emails, password resets, billing
notifications, service alerts, and feature announcements;
(c) communicate about updates to our Terms of Service or this Privacy Policy; and
(d) send product newsletters and marketing emails, where you have consented or where we
have a legitimate interest and you have not opted out.
5.4 Service Improvement and Analytics
We use aggregated and anonymized usage data to:
(a) understand how Customers and Authorized Users interact with the Services;
(b) identify and fix bugs and performance issues;
(c) develop new features and improve existing ones;
(d) benchmark platform performance; and
(e) produce internal and external product analytics reports.
We do not use identifiable Customer Content or Call Data to train AI models without express
Customer opt-in. See Section 10 for our complete training policy.
5.5 Safety, Security, and Fraud Prevention
We use information to:
(a) detect and prevent unauthorized access, fraud, and abuse of the Services;
(b) monitor for violations of our Acceptable Use Policy;
(c) investigate suspicious activity or potential illegal conduct;
(d) protect the security and integrity of the platform and its users; and
(e) comply with legal obligations related to security incident reporting.
5.6 Legal Compliance
We use information to:
(a) comply with applicable laws, regulations, and legal process;
(b) respond to lawful requests from government authorities and law enforcement;
(c) enforce our Terms of Service;
(d) protect our legal rights and interests in disputes; and
(e) fulfill tax and financial reporting obligations.
5.7 Aggregate Research and Benchmarking
We may compile Aggregate Data about platform usage, call volumes, AI accuracy metrics, and
industry benchmarks. This Aggregate Data is de-identified and does not contain information
attributable to any specific Customer or individual.
6. Legal Bases for Processing (GDPR)
For individuals in the European Economic Area (EEA), the United Kingdom, or Switzerland, we
process Personal Data only where we have a valid legal basis as required by the GDPR or
equivalent applicable law.
6.1 Performance of a Contract
We process Account data, billing data, and Customer-provided configurations to the extent
necessary to perform our obligations under the Terms of Service, including providing the
Services you have subscribed to.
6.2 Legitimate Interests
We process Usage Data, technical data, and security logs based on our legitimate interest in:
(a) operating, maintaining, and improving a secure and reliable platform;
(b) detecting and preventing fraud and abuse;
(c) communicating with Customers about relevant product features and updates (where you
have not opted out); and
(d) conducting internal analytics to understand platform performance.
Where we rely on legitimate interests, we have considered the impact on your interests, rights,
and freedoms, and we believe our processing is proportionate.
6.3 Compliance with Legal Obligations
We process certain data, including records of transactions and security logs, to comply with our
legal obligations under applicable laws.
6.4 Consent
Where we send marketing communications or use non-essential cookies, we rely on your
consent, which you may withdraw at any time as described in Section 16.
6.5 Data Processing on Behalf of Customers (Processor Role)
When processing Contact Subject data at the direction of a Customer, Truedy AI acts as a data
processor. The Customer is the data controller and is responsible for identifying and
documenting the legal basis for such processing. Customers may request a Data Processing
Agreement (DPA) by contacting privacy@truedy.ai. Truedy AI will consider such requests on a
case-by-case basis.
7. How We Share Your Information
7.1 We Do Not Sell Personal Data
Truedy AI does not sell, rent, trade, or lease Personal Data to third parties for their own
marketing or commercial purposes.
7.2 Service Providers and Sub-Processors
We share Personal Data with trusted third-party vendors who process data on our behalf to
support the delivery of the Services. These vendors are contractually bound to process data
only as directed by us, to maintain appropriate security measures, and not to use data for their
own independent purposes. Our key service providers and sub-processors include:
Vendor Purpose Data Shared
Stripe Payment processing and billing Billing name, email, payment card
metadata
Clerk Identity and authentication management Email address, organizational
identifiers
Supabase Database hosting and storage All platform data including call
records and configurations
Telnyx Telephony infrastructure (managed and
BYOC)
Phone numbers, call metadata,
call audio
Ultravox Conversational AI voice processing Call audio streams, agent
configuration
ElevenLabs Voice synthesis Agent voice configuration, text-to
speech content
Deepgram Speech-to-text transcription Call audio recordings
OpenRouter AI model API for call analysis,
sentiment scoring, and summarization
Call transcripts, conversation data
GoHighLevel CRM integration Contact data, OAuth tokens,
trigger payloads
Vendor
Hetzner
Mixpanel
Purpose
Backend server infrastructure
Product analytics
Data Shared
All backend application data
Usage events, feature interaction
data
We may update our list of sub-processors from time to time. We require sub-processors to
maintain data security practices appropriate to the nature of data processed.
7.3 GoHighLevel Integration Data Sharing
When you enable the GoHighLevel Integration, data flows between Truedy AI and GoHighLevel
as directed by your workflow configuration. This may include:
Contact identifiers and phone numbers sent to GHL when a call event triggers a workflow
Call outcome data, summary text, sentiment scores, and recording URLs included in trigger
payloads sent to GHL Workflow Builder
OAuth tokens exchanged for accessing GHL API endpoints on your behalf
You direct and control these data flows through your GHL workflow configuration. Truedy AI
does not share data with GHL beyond what your configured workflows require.
7.4 Business Transfers
In the event of a merger, acquisition, reorganization, sale of all or substantially all of True Pay 4
Performance Inc.’s assets, or similar transaction, Personal Data may be transferred to the
acquiring entity as part of that transaction. We will provide notice of any such transfer and the
privacy choices available to you.
7.5 Legal Requirements and Safety
We may disclose Personal Data if we believe in good faith that disclosure is necessary to:
(a) comply with applicable law, regulation, legal process, or governmental request;
(b) enforce our Terms of Service or protect our legal rights;
(c) detect, prevent, or address fraud, security incidents, or technical problems; or
(d) protect the safety, rights, or property of Truedy AI, our Customers, or the public.
We will, where legally permissible, notify you before disclosing your data in response to legal
process.
7.6 With Your Consent
We will share your Personal Data with third parties not described above only where you have
given express consent to such sharing.
8. Call Recording, Voice Data, and AI Processing
8.1 Call Recording
If you enable the call recording feature, audio recordings of calls conducted through the
Services will be captured and stored in encrypted form on our cloud infrastructure. Call
recordings are:
(a) stored for the duration of your active Subscription (see Section 13.2);
(b) accessible to you and your Authorized Users through the platform dashboard;
(c) used to generate transcripts and AI analytics (where enabled); and
(d) permanently deleted upon expiry of the retention period or upon your explicit deletion
request.
8.2 Transcript Generation
We use automated speech-to-text AI services to generate written transcripts from call
recordings or live call audio. Transcripts are:
(a) probabilistic outputs and may contain errors;
(b) stored alongside call metadata in your Account;
(c) used to generate sentiment analysis, summaries, and call outcome classifications; and
(d) subject to the same retention and deletion rules as call recordings.
8.3 AI Analysis and Derived Data
Beyond transcription, our AI systems generate derived analytical outputs from call data,
including:
(a) Sentiment Analysis: A probabilistic score indicating whether the call tone was positive,
neutral, or negative, generated by large language model analysis of the transcript.
(b) Call Outcome Classification: A categorical classification of how the call ended (e.g.,
contacted, voicemail, no answer, busy, failed).
(c) Call Summary: A brief machine-generated natural language summary of the call content.
(d) Key Moments: Extraction of notable phrases, commitments, or events from the transcript.
All AI-generated outputs are probabilistic and are provided for informational purposes only.
Customers are responsible for validating these outputs before using them for business
decisions.
8.4 Customer Responsibility for Consent
Call recording and AI processing of call audio involves the processing of personal data of call
participants, including third-party call recipients who are not Customers of Truedy AI. By
enabling call recording, you represent and warrant that:
(a) you have obtained all legally required consents from call participants before recording
begins, including all-party (two-party) consent in jurisdictions that require it;
(b) you have complied with all applicable call recording notification requirements; and
(c) your recording and processing activities comply with all applicable privacy and
telecommunications laws.
Truedy AI is not liable for your failure to obtain required consents. You indemnify Truedy AI for
any claims, fines, or penalties arising from your unlawful recording of calls.
8.5 No Use of Call Data for Model Training
Truedy AI does not use your call recordings, transcripts, or call content to train, fine-tune, or
improve AI models sold to third parties. See Section 10 for our complete model training policy.
9. Voice Data and Biometric Privacy Laws
9.1 Voice Recordings May Constitute Biometric Data
Voice recordings made through the Services may constitute biometric identifiers, biometric
information, or biometric data under applicable state and international laws, including various
U.S. state biometric privacy laws and similar laws enacted in other jurisdictions.
9.2 Truedy AI’s Practices Regarding Voice Data
Truedy AI does not extract standalone voiceprints or biometric identifiers from call recordings for
the purpose of identifying individuals. Call recordings processed through the Services are used
for transcription, sentiment analysis, and call analytics — not for biometric identification. Audio
data processed through our voice AI provider (Ultravox) is used solely to enable conversational
AI functionality and is subject to Ultravox’s own data processing terms.
9.3 Customer Responsibility for Biometric Compliance
Customers who use the Services to make or receive calls involving residents of Illinois, Texas,
Washington, or other jurisdictions with biometric privacy laws are solely responsible for:
(a) determining whether their use of the Services gives rise to biometric data collection or
processing obligations under applicable law;
(b) providing required written notice to individuals and obtaining written consent before
collecting biometric data where required;
(c) publishing and maintaining a publicly available biometric data retention and destruction
policy as required by applicable law; and
(d) complying with all applicable restrictions on the disclosure, sale, or transfer of biometric
data.
Truedy AI makes no warranties regarding the biometric privacy law compliance of any
Customer’s call campaigns.
9.4 Retention of Voice Data
Call audio retained through the Services is stored for the duration of your active Subscription
(see Section 13.2). Audio files are encrypted at rest and in transit using AES-256. Upon deletion
(upon explicit request or upon account termination), audio files are removed from active
systems and will be overwritten from backup systems within 90 days.
10. AI Model Training — Your Data and Your Rights
10.1 Default Policy: No Training Without Opt-In
Truedy AI does not use your Content or Call Data — including call recordings, transcripts,
conversation logs, or agent configurations — to train, fine-tune, or improve any AI model that is
offered to third parties, without your express prior written opt-in consent.
10.2 Internal Platform Improvement
We may analyze aggregate, de-identified, and anonymized usage patterns across the platform
(such as call outcome classification accuracy, transcription quality, or platform feature usage) to
improve our Services. This analysis operates at the aggregate level and does not expose
individual Customer Content in any identifiable form.
10.3 No Third-Party Training Sharing
We do not share your Content with third-party AI providers (including Ultravox or ElevenLabs)
for those providers’ independent model training purposes.
10.4 How to Opt In or Opt Out
If you have previously opted in to data use for model training purposes, or wish to opt out at any
time, you may do so by:
(a) submitting a written request to
privacy@truedy.ai with the subject line “Data Training Opt
Out”; or
(b) updating your preferences by contacting
privacy@truedy.ai.
Opt-out requests will be processed within 30 days. Withdrawal of consent does not affect
processing that occurred before the opt-out was processed.
11. GoHighLevel Integration and Data Flows
11.1 Data Received from GoHighLevel
When you authorize the GHL Integration, Truedy AI may receive the following data from
GoHighLevel on your behalf:
(a) Contact records including names, phone numbers, email addresses, and custom field
values;
(b) Your GoHighLevel location (sub-account) identifier;
(c) Workflow configuration data that governs when Truedy AI actions are triggered; and
(d) OAuth tokens that authorize Truedy AI to act on your behalf within GoHighLevel.
11.2 Data Sent to GoHighLevel
Based on your workflow configuration, Truedy AI sends data to GoHighLevel including:
(a) Call Ended Trigger Payloads: Call ID, call direction, phone numbers, agent ID, call
duration, call outcome, sentiment score, call summary, is-success flag, end reason, and
recording URL.
(b) Appointment Booking Payloads: Call ID, contact phone number, appointment date and
time, appointment notes, and agent ID.
(c) Human Handoff Payloads: Call ID, contact phone number, reason for handoff, call
summary, and agent ID.
(d) Contact Actions: Contact creation, tagging, or field updates within GoHighLevel as directed
by your workflow configuration.
11.3 GHL OAuth Token Storage
Truedy AI stores GoHighLevel OAuth access tokens and refresh tokens in encrypted form in our
database. These tokens are used only to perform integration functions that you have configured
and authorized. Tokens are refreshed automatically as needed and are revoked from our
systems when you disconnect the integration.
11.4 GHL Data Processing Relationship
Truedy AI acts as a data processor with respect to contact data received from and sent to
GoHighLevel at your direction. You, as the Customer, are the data controller responsible for the
lawfulness of processing contact data through both platforms.
12. Cookies and Tracking Technologies
12.1 What We Use
Truedy AI uses cookies and similar tracking technologies on our website and web application.
These include:
(a) Essential Cookies
These cookies are necessary for the website and platform to function correctly. They enable
core features such as user authentication, session management, and security. Essential
cookies cannot be disabled.
(b) Functional Cookies
These cookies remember your preferences, settings, and choices (such as language
preferences or dashboard configurations) to provide a more personalized experience.
(c) Analytics Cookies
We use analytics cookies to understand how visitors interact with our website and platform,
including which pages are visited most frequently, how users navigate the product, and where
errors occur. This information is used in aggregate form to improve the Services.
(d) Performance and Monitoring Cookies
These cookies help us identify and resolve performance issues, measure load times, and
monitor platform health.
(e) Marketing Cookies (Website Only)
On our public marketing website, we may use cookies associated with advertising platforms to
understand the effectiveness of our marketing campaigns. These cookies do not apply to the
authenticated platform application.
12.2 Managing Cookies
You can manage cookies through your browser settings. Most browsers allow you to refuse
cookies, delete existing cookies, and configure alerts for new cookies. Note that disabling
essential cookies will impair your ability to use the platform. For analytics and marketing
cookies, you can also use available opt-out mechanisms provided by our analytics partners.
12.3 Do Not Track
Some browsers transmit “Do Not Track” (DNT) signals. Truedy AI does not currently respond to
DNT signals, as there is no consistent industry standard for how to respond to such signals.
However, you can control your privacy preferences through cookie settings and the opt-out
mechanisms described above.
13. Data Retention
13.1 Retention Principles
We retain Personal Data only for as long as necessary to fulfill the purposes for which it was
collected, comply with legal obligations, resolve disputes, and enforce our agreements.
13.2 Retention Schedule
Data Category
Account and profile information
Billing and payment records
Call recordings (audio files)
Call transcripts and AI analytics
Retention Period
Duration of Subscription plus 3 years
7 years (tax and accounting compliance)
Duration of Subscription
Duration of Subscription plus 1 year
Campaign and contact history
Duration of Subscription plus 1 year
Data Category
API access logs and usage data
Retention Period
12 months rolling
Support and communications records 3 years from last interaction
Security and fraud logs
TCPA consent documentation
GHL OAuth tokens
13.3 Post-Termination
Upon termination of your Subscription:
12 months rolling
5 years minimum from date of last call
Deleted upon integration disconnection
(a) Your data will remain accessible for export for 30 days following the termination date.
(b) After the 30-day export window, account data and call records will be deleted from active
systems in the ordinary course of our data management operations.
(c) Backup copies may persist for up to 90 days after deletion from active systems and will be
overwritten during normal backup rotation.
(d) Anonymized Aggregate Data derived from your usage will be retained indefinitely as it
contains no Personal Data.
13.4 Legal Hold
We may retain Personal Data beyond the standard retention periods described above if it is
subject to a legal hold, active litigation, regulatory investigation, or a lawful preservation
request.
14. Data Security
14.1 Security Measures
Truedy AI implements administrative, technical, and physical safeguards designed to protect
Personal Data against unauthorized access, disclosure, alteration, and destruction. Our security
measures include:
(a) Encryption
All data is encrypted in transit using TLS 1.2 or higher. Personal Data at rest — including call
recordings, transcripts, and stored OAuth tokens — is encrypted using AES-256 or equivalent
industry-standard algorithms.
(b) Access Controls
Access to Personal Data is restricted to personnel who need it to perform their job functions.
We use role-based access controls, multi-factor authentication for internal systems, and the
principle of least privilege.
(c) Infrastructure Security
Our backend infrastructure is hosted on Hetzner servers and Supabase, both of which maintain
their own enterprise-grade security programs. Database access is restricted by network policy
and authenticated credentials.
(d) Monitoring and Logging
We maintain audit logs of access to sensitive data and platform systems. Anomalous access
patterns and potential security incidents are monitored using automated alerting.
(e) Vulnerability Management
We apply security patches and updates as part of our development process and respond to
identified vulnerabilities as they arise.
(f) Third-Party Security
We work with established cloud and infrastructure providers (Supabase, Hetzner, Telnyx) that
maintain their own security programs.
15. International Data Transfers
15.1 Location of Processing
Truedy AI’s primary operations and data storage are located in the United States. If you access
the Services from outside the United States, your Personal Data will be transferred to and
processed in the United States and potentially in other countries where our sub-processors
operate.
15.2 Transfers Outside Your Country
If you are located outside the United States, be aware that your Personal Data will be
transferred to and processed in the United States. By using the Services, you acknowledge this
transfer. If applicable data protection laws in your jurisdiction require a legal basis for such
transfers, please contact
privacy@truedy.ai to discuss your requirements.
15.3 Sub-Processor Locations
Some of our sub-processors, including Stripe, Telnyx, and ElevenLabs, are based in the United
States. These providers maintain their own privacy and data protection practices.
16. Your Rights and Choices
16.1 Access and Correction
You have the right to access the Personal Data we hold about you and to request correction of
inaccurate or incomplete data. You can access and update most of your account information
directly through the platform settings. For requests not addressable through the platform,
contact us at
privacy@truedy.ai.
16.2 Deletion
You may request deletion of your Personal Data, subject to our legal obligations to retain
certain data (such as billing records and TCPA consent documentation) and any active legal
holds. When you delete your Account, we will delete your Personal Data in accordance with the
retention schedule in Section 13.
16.3 Data Portability
You may request a machine-readable export of Personal Data that you have provided to us and
that is processed by automated means on the basis of your consent or for contract
performance. You can initiate a data export through the platform or by contacting us.
16.4 Objection to Processing
Where we process Personal Data based on legitimate interests, you have the right to object to
such processing. We will cease processing unless we can demonstrate compelling legitimate
grounds that override your interests, rights, and freedoms.
16.5 Restriction of Processing
In certain circumstances, you may request that we restrict the processing of your Personal Data
(for example, while we verify the accuracy of data you have disputed).
16.6 Withdrawal of Consent
Where we rely on your consent as the legal basis for processing, you may withdraw that
consent at any time without affecting the lawfulness of processing carried out before the
withdrawal.
16.7 Marketing Opt-Out
You may unsubscribe from marketing emails at any time by clicking the “unsubscribe” link in
any marketing email or by contacting us at
privacy@truedy.ai. Note that you may still receive
transactional and service-related communications even after opting out of marketing.
16.8 AI Training Opt-Out
You may opt out of any use of your Content for AI model training at any time by submitting a
written request to
privacy@truedy.ai with the subject line “Data Training Opt-Out,” or by using
the data preference controls in your Account settings where available. See Section 10 for our
complete training policy.
16.9 Contact Subject Requests
If you are a Contact Subject whose data was uploaded to the platform by one of our Customers,
your rights with respect to that data are best directed to the Customer who collected your
information, as that Customer is the data controller. If you contact us directly, we will forward
your request to the relevant Customer and assist in facilitating a response where possible.
16.10 How to Submit a Request
To exercise any of the rights described in this Section, please submit a request to
privacy@truedy.ai with the subject line “Privacy Rights Request.” We will respond within 30
days, or within the timeframe required by applicable law. We may request identity verification
before processing your request to ensure we are responding to the correct individual.
17. California Privacy Rights (CCPA/CPRA)
17.1 Applicability
This Section applies to California residents whose Personal Information is collected, used, or
disclosed by Truedy AI subject to the California Consumer Privacy Act (CCPA) as amended by
the California Privacy Rights Act (CPRA).
17.2 Categories of Personal Information Collected
In the preceding 12 months, Truedy AI has collected the following categories of Personal
Information as defined by the CCPA:
(a) Identifiers: Name, email address, IP address, account ID, device identifiers.
(b) Commercial Information: Subscription plan, payment history, service usage records.
(c) Internet or Other Electronic Network Activity: Browsing history on our platform, feature
usage logs, API request logs.
(d) Audio and Electronic Data: Call recordings (where enabled by the Customer).
(e) Professional or Employment-Related Information: Job title, company name (voluntarily
provided).
(f) Inferences Drawn from Personal Information: Usage patterns, preferences, platform
engagement indicators.
17.3 Sources of Personal Information
We collect Personal Information from: (a) you directly; (b) your Authorized Users; (c) Third-Party
Services (such as GoHighLevel and Stripe); and (d) automated collection technologies (such as
cookies and log files).
17.4 Business Purposes for Collection
We collect Personal Information for the purposes described in Section 5 of this Privacy Policy,
including providing the Services, billing, customer support, security, and service improvement.
17.5 Disclosure of Personal Information
In the preceding 12 months, Truedy AI has disclosed Personal Information to service providers
and sub-processors as described in Section 7.2 for business purposes. We do not sell Personal
Information. We do not share Personal Information for cross-context behavioral advertising
purposes.
17.6 Your California Rights
California residents have the following rights under the CCPA/CPRA:
(a) Right to Know: You have the right to request disclosure of the categories and specific
pieces of Personal Information we have collected about you, the categories of sources, the
business or commercial purposes for collection, and the categories of third parties with whom it
was shared.
(b) Right to Delete: You have the right to request deletion of Personal Information we have
collected from you, subject to exceptions under the CCPA/CPRA (such as completing
transactions, complying with legal obligations, or maintaining required TCPA consent records).
(c) Right to Correct: You have the right to request correction of inaccurate Personal
Information.
(d) Right to Opt Out of Sale or Sharing: Truedy AI does not sell Personal Information and
does not share it for cross-context behavioral advertising. You therefore do not need to exercise
an opt-out right for these purposes.
(e) Right to Limit Use of Sensitive Personal Information: Truedy AI does not use Sensitive
Personal Information for purposes beyond those permitted by the CCPA/CPRA without your
consent.
(f) Right to Non-Discrimination: Truedy AI will not discriminate against you for exercising any
of your California privacy rights. We will not deny you goods or services, charge you different
prices, or provide you with a lower quality of service because you exercised your rights.
17.7 Submitting California Requests
California residents may submit requests to exercise their rights at
privacy@truedy.ai. We will
respond within 45 days of receipt of a verifiable consumer request, with the possibility of a 45
day extension in certain circumstances. We will not charge a fee for processing verifiable
consumer requests unless they are manifestly unfounded, excessive, or repetitive.
18. European Economic Area, UK, and Swiss Privacy Rights
(GDPR)
18.1 Applicability
This Section applies to individuals in the European Economic Area (EEA), the United Kingdom
(UK), and Switzerland whose Personal Data is processed by Truedy AI in connection with the
Services.
18.2 Controller and Processor Roles
As described in Section 1.3, Truedy AI acts as a data controller with respect to Account and
Usage Data and as a data processor with respect to Contact Subject data processed at the
direction of Customers.
18.3 Your GDPR Rights
Under the GDPR (and equivalent UK and Swiss law), you have the following rights:
(a) Right of Access (Article 15 GDPR): You have the right to obtain confirmation of whether
we process your Personal Data and, if so, to receive a copy of that data along with
supplementary information about how it is processed.
(b) Right to Rectification (Article 16 GDPR): You have the right to have inaccurate Personal
Data corrected and incomplete data completed.
(c) Right to Erasure (Article 17 GDPR): You have the right to request deletion of your
Personal Data where it is no longer necessary for the purposes for which it was collected,
where you withdraw consent (and there is no other legal basis), where you object and there are
no overriding legitimate grounds, or where the data has been unlawfully processed.
(d) Right to Restriction of Processing (Article 18 GDPR): You have the right to request that
we restrict processing of your Personal Data in certain circumstances, such as while a dispute
about accuracy is resolved.
(e) Right to Data Portability (Article 20 GDPR): You have the right to receive Personal Data
that you have provided to us in a structured, commonly used, and machine-readable format,
and to transmit it to another controller, where processing is based on consent or contract and is
carried out by automated means.
(f) Right to Object (Article 21 GDPR): You have the right to object to processing of your
Personal Data based on legitimate interests, including profiling based on those interests. You
also have the absolute right to object to processing for direct marketing purposes.
(g) Rights Related to Automated Decision-Making (Article 22 GDPR): You have the right not
to be subject to a decision based solely on automated processing, including profiling, which
produces legal effects or similarly significant effects. Truedy AI does not make decisions of this
nature using your Personal Data.
18.4 Supervisory Authority
If you believe our processing of your Personal Data violates applicable data protection law, you
have the right to lodge a complaint with the supervisory authority in your country of residence,
place of work, or the place of the alleged infringement. A list of EEA supervisory authorities is
available at the European Data Protection Board website (edpb.europa.eu).
18.5 Data Processing Agreement
Customers who are subject to GDPR may request a Data Processing Agreement (DPA) from
Truedy AI to govern our processing of Personal Data on their behalf. Please contact
privacy@truedy.ai to request a DPA.
19. Children’s Privacy
The Services are not directed to individuals under the age of 18. We do not knowingly collect
Personal Data from children under 18. If you are a parent or guardian and believe that your
child has provided us with Personal Data without your consent, please contact us at
privacy@truedy.ai. Upon confirmation, we will take steps to delete that information from our
systems in reasonable time following verified confirmation.
Customers must not submit voice recordings, contact data, or other personal information
relating to individuals under the age of 18 through the Services.
20. Third-Party Links and Services
The Services may contain links to or integrations with third-party websites, applications, or
services that are not operated or controlled by Truedy AI. This Privacy Policy does not apply to
such third-party services. We encourage you to review the privacy policies of any third-party
services you use in connection with Truedy AI. Truedy AI is not responsible for the privacy
practices or content of third-party services.
21. Changes to This Privacy Policy
21.1 Right to Update
We may update this Privacy Policy from time to time to reflect changes in our data practices,
legal requirements, or platform features. The updated Policy will be posted on our website with
a revised “Last Updated” date.
21.2 Notice of Material Changes
Where changes to this Policy are material (for example, changes to the types of data we collect,
how we use it, with whom we share it, or new categories of processing activity), we will provide
notice through one or more of the following:
(a) email to the address associated with your Account;
(b) a prominent notice on the platform dashboard; or
(c) a notification in the next billing communication.
21.3 Continued Use
Your continued use of the Services following notice of changes constitutes your acceptance of
the updated Privacy Policy. If you do not agree with any changes, you must discontinue use of
the Services and contact us to close your Account.
22. Contact Us and Data Subject Requests
For any questions about this Privacy Policy, to exercise your privacy rights, or to submit a data
subject access request, please contact our Privacy Officer:
True Pay 4 Performance Inc.
Attn: Privacy Officer
Operating as Truedy AI
Phone: (833) 838-7747
Email:
privacy@truedy.ai
General Support:
support@truedy.ai
General Inquiries:
info@truep4p.com
Registered Address:
True Pay 4 Performance Inc.
Newport Beach, California
United States
Website: truep4p.com
We will acknowledge receipt of your request within 5 business days and provide a substantive
response within 30 days (or as required by applicable law). If your request requires additional
time, we will notify you of the extension and the reason for it.
This Privacy Policy was last updated on May 5, 2026. Prior versions are available upon request