Privacy Policy

Last Updated: December 11, 2025

1. Who We Are

Solfaia ("We") takes data privacy seriously. This policy explains how David Paulos Da Fonseca (trading as Solfaia, *Entreprise Individuelle*) processes data.
VAT / TVA Number: LU31854716
Contact: contact@solfaia.com

2. Our "Privacy-First" Architecture

Solfaia is designed with a privacy-first philosophy, adhering to the principle of **Ephemeral Processing** for end-user conversations:

Audio Data: Raw audio from calls is processed in real-time and is not permanently stored on our servers unless explicitly requested for quality assurance.
Transcripts: Text logs are retained only as long as necessary to extract business insights (bookings, summaries), after which they are minimized or deleted according to your retention settings.
Isolation: Each client’s data is processed in isolated environments to prevent cross-contamination.

3. Data We Process

To operate the Service and comply with our legal obligations, we process the following:

Client Data: Name, Billing Address, VAT Number (if applicable), Email, and Phone number.
End-User Data: Phone numbers, voice data (transient), and chat logs of your customers interacting with the AI.

4. Third-Party Sub-Processors

We use trusted, compliant third-party infrastructure to deliver and manage the service. These partners only process data under strict instructions. The key processing categories are:

Payments: Stripe (Processing financial and billing data).
AI & Communications (Core Processing): OpenAI, Anthropic, **Gemini** (NLP processing), **ElevenLabs** (Voice synthesis), Twilio / Vapi (Telephony/Voice), String (Messaging management).
**Infrastructure & Automation:** Workflow automation platforms (e.g., n8n), CRM systems, and hosting services.

A complete, dynamic list of all engaged sub-processors is maintained and available upon written request to ensure transparency and compliance with GDPR. This prevents the need for constant updates to this core policy document.

5. Your Rights (GDPR)

Under the GDPR, you have the right to access, rectify, or delete your personal data. To exercise these rights, please contact our Data Protection Officer at: contact@solfaia.com.