Legal

Data processing agreement

How Renggo processes personal data on behalf of its customers, under Article 28 of the GDPR.

1. Parties and scope

This data processing agreement ("DPA") is between the customer named in the account or order form ("Customer") and Renggo Labs OÜ, a private limited company registered in Estonia (registry code 17327722), Liivalaia tn 26-32, Kesklinna linnaosa, 10118 Tallinn, Harju maakond, Estonia ("Renggo"). It is part of the Terms of service or other agreement under which Renggo provides its services (the "Agreement") and applies whenever Renggo processes personal data on the Customer's behalf.

The Customer is the controller of that data and Renggo is its processor. Where the Customer itself acts as a processor for a third party, Renggo is its sub-processor and the Customer passes on the relevant instructions.

Terms such as "personal data", "processing", "controller", "processor", "data subject" and "personal data breach" have the meanings given in the General Data Protection Regulation (EU) 2016/679 ("GDPR").

2. Subject matter, duration, nature and purpose

  • Subject matter: providing the Renggo platform and AI agents that handle conversations with the Customer's callers and customers.
  • Duration: the term of the Agreement, plus the period until the data is deleted or returned under this DPA.
  • Nature: collecting, recording, transcribing, storing, structuring, analysing with AI models, transmitting to connected systems, retrieving and deleting.
  • Purpose: answering and handling calls and messages on the Customer's behalf, carrying out the actions the Customer configures, keeping conversation records, and providing support.

3. Types of personal data

  • Conversation content: call audio processed in real time, transcripts, chat and messaging content, emails, and the inputs and results of actions the agent takes.
  • Call recordings, only for agents where the Customer has switched recording on.
  • Contact details: names, phone numbers, email addresses and messaging account identifiers.
  • Information that end users give in a conversation and that the agent extracts as variables, such as booking or order details.
  • Conversation metadata: channel, time, duration, end reason, usage and cost.
  • Account data of the Customer's users: names, work emails and roles.

The Customer decides what data its agents collect. It will not configure agents to collect special categories of personal data unless it has a legal basis and has told Renggo in writing.

4. Categories of data subjects

  • The Customer's callers, customers and other people who talk or write to its agents.
  • The Customer's staff and contractors who receive handed-over conversations or use the platform.
  • Other people mentioned in conversations or in the Customer's knowledge bases.

5. The Customer's instructions

Renggo processes the personal data only on the Customer's documented instructions, including for transfers outside the EEA, unless EU or member state law requires otherwise (in which case Renggo informs the Customer first, unless the law forbids it). The Agreement, this DPA and the Customer's configuration and use of the platform are the Customer's instructions. Renggo tells the Customer if it believes an instruction breaks data protection law.

The Customer is responsible for the lawfulness of the processing it instructs, including having a legal basis, informing end users and obtaining any consents needed, for example for call recording.

6. Renggo's obligations and confidentiality

  • Renggo makes sure that everyone authorised to process the personal data is bound by confidentiality.
  • Renggo does not use the personal data for its own purposes and does not sell it.
  • Renggo helps the Customer meet its obligations under Articles 32 to 36 GDPR, taking into account the nature of the processing and the information available to it.
  • Renggo keeps a record of processing activities as Article 30(2) GDPR requires.

7. Security measures

Renggo applies appropriate technical and organisational measures to protect the personal data, taking into account the state of the art, costs and the risks to data subjects. They include:

  • Encryption of data in transit between users, the platform and connected services.
  • Access controls: role-based access in the dashboard (admin, member, read-only viewer), scoped to the Customer's organisation, and access by Renggo staff only where needed to run and support the service.
  • Logging: a log of each conversation with its transcript, the actions the agent took and the reason the conversation ended, which the Customer can review and export.
  • Recording control: call recording is switched off unless the Customer switches it on for an agent.
  • Each customer's data and users scoped to its own organisation, versioned agent configurations with one-click rollback, and for Enterprise customers the option of an orchestrator reserved for their live conversations.
  • The option to use the Customer's own model provider keys, so that model processing runs under the Customer's own provider account.

Renggo reviews these measures regularly and may change them, as long as the overall level of protection does not decrease.

8. Sub-processors

The Customer gives Renggo general authorisation to engage sub-processors. The current list is on the Sub-processors page.

  • Renggo gives at least 30 days' notice before adding or replacing a sub-processor, by updating that page and notifying the Customer's account admins by email or in the platform.
  • The Customer may object on reasonable data protection grounds within that period. The parties will then discuss it in good faith; if they cannot resolve it, the Customer may terminate the affected Services and receive a refund of any prepaid fees for them.
  • Renggo puts data protection obligations on each sub-processor that are at least as protective as this DPA and remains responsible to the Customer for its sub-processors' performance.

Services the Customer connects or chooses itself, such as its own telephony account, messaging channels or model provider keys, are the Customer's own providers and not Renggo's sub-processors.

9. Help with data subject requests and assessments

Taking into account the nature of the processing, Renggo helps the Customer answer requests from data subjects exercising their rights. The platform lets the Customer find, export and delete conversation records itself. If Renggo receives such a request directly, it passes it to the Customer without undue delay and does not answer it itself unless the Customer instructs it to.

Renggo also gives the Customer reasonable help with data protection impact assessments and prior consultations with supervisory authorities related to the Services.

10. Personal data breaches

Renggo notifies the Customer without undue delay after becoming aware of a personal data breach affecting the Customer's personal data. The notice describes, as far as then known, the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, and the measures taken or proposed. Renggo provides further information as it becomes available and takes reasonable steps to contain the breach and limit its effects. Notifying a breach is not an admission of fault.

11. Deletion or return of data

While the Agreement is in force, the Customer can export its conversation records. When the Agreement ends, Renggo deletes the Customer's personal data within 30 days, unless the Customer asks in that period for an export, or EU or member state law requires Renggo to keep it. Copies in backups are deleted as the backups are overwritten in the normal cycle and stay protected under this DPA until then.

12. Information and audits

Renggo makes available to the Customer the information reasonably necessary to show compliance with Article 28 GDPR and this DPA, and allows for and contributes to audits, including inspections, by the Customer or an independent auditor it appoints.

  • The Customer gives at least 30 days' written notice and agrees the scope, timing and duration with Renggo.
  • Audits take place no more than once a year, unless a supervisory authority requires it or there has been a personal data breach.
  • Auditors are bound by confidentiality, and audits must not disrupt the Services or give access to other customers' data.
  • The Customer bears its own costs of the audit.

13. International transfers

Renggo transfers personal data outside the EEA only in line with Chapter V GDPR: to a country with an adequacy decision of the European Commission, or under the European Commission's Standard Contractual Clauses with the sub-processor concerned, together with additional measures where needed. Where the Customer is outside the EEA, the parties agree to put in place the Standard Contractual Clauses that apply to the transfer between them, if required.

14. Liability

Each party's liability under this DPA is subject to the limitations and exclusions of liability in the Agreement, to the extent the GDPR allows.

15. Term, precedence and governing law

This DPA applies for as long as Renggo processes personal data on the Customer's behalf. If it conflicts with the Agreement on data protection, this DPA prevails; the Standard Contractual Clauses, where they apply, prevail over both. This DPA is governed by the laws of Estonia, and disputes are decided by Harju County Court (Harju Maakohus) in Tallinn, unless mandatory law says otherwise.

16. Contact

Questions about this DPA and data protection requests: support@renggo.com. Renggo Labs OÜ, a private limited company registered in Estonia (registry code 17327722), Liivalaia tn 26-32, Kesklinna linnaosa, 10118 Tallinn, Harju maakond, Estonia.