DRAFT: needs attorney review before publishing. Bracketed items are placeholders.

Privacy Policy

Effective date: [EFFECTIVE DATE] · Last updated: [LAST UPDATED DATE]

This Privacy Policy explains how [LEGAL ENTITY NAME] ("Apex," "we," "us") collects, uses, and shares information through apex-ai.tech, the Apex application, and related services (the "Services"). Apex is a sales call coaching platform used by businesses ("Customers") and their users (for example, sales reps and managers).

Controller / processor: for call and CRM data that Customers upload or generate in the Services, Apex generally acts as a service provider / processor on the Customer's behalf, and the Customer controls that data. [CONFIRM ROLE WITH COUNSEL; REFERENCE DATA PROCESSING ADDENDUM IF ANY.] For website visitors, demo requests, and account administration, Apex acts as the business / controller.

1. Information we collect

Information Customers and users provide or generate in the Services

Account and contact information

Information collected automatically

2. How we use information

3. Subprocessors and sharing

We share information with service providers who process it on our behalf under contract. Current subprocessors include:

SubprocessorPurposeData location
Twilio Inc.Telephony: phone numbers, call placement/routing, call recording, voicemail[REGION]
[AI MODEL PROVIDER(S) — NAME EACH]Transcription, call scoring, summaries, drafting[REGION]
DigitalOcean, LLCHosting, compute, storage[DATACENTER REGION]
[EMAIL / PAYMENT / ANALYTICS PROVIDERS, IF ANY][PURPOSE][REGION]

We may also disclose information to comply with law or legal process, to protect rights and safety, or in connection with a merger, acquisition, or sale of assets. We do not sell personal information or share it for cross-context behavioral advertising. [CONFIRM]

4. Retention

DataRetention period
Call recordings and voicemail audio[RETENTION PERIOD / CUSTOMER-CONFIGURABLE?]
Transcripts, AI scores, coaching reports[RETENTION PERIOD]
CRM data[RETENTION PERIOD]
Demo-request / contact form submissions[RETENTION PERIOD]
Backups and logs[RETENTION PERIOD]

5. Deletion and export

Customers may export their data [DESCRIBE EXPORT METHOD] and request deletion of their workspace data by contacting [CONTACT EMAIL]. Following account termination, we delete Customer data within [NUMBER] days, except where retention is required by law; residual copies in backups are deleted within [NUMBER] days. If you are an individual whose information was processed on behalf of a Customer (for example, a person who was called by a sales rep), please contact that Customer directly; we will assist them as required.

6. Security

We use [DESCRIBE SECURITY MEASURES, E.G. ENCRYPTION IN TRANSIT / AT REST, ACCESS CONTROLS] to protect information. No system is completely secure.

7. Your California privacy rights (CCPA/CPRA)

If you are a California resident, subject to exceptions, you have the right to:

To exercise these rights, email [CONTACT EMAIL] or [OTHER METHOD, E.G. TOLL-FREE NUMBER IF REQUIRED]. We will verify your request by [VERIFICATION METHOD]. You may use an authorized agent. Where we process data as a service provider for a Customer, we will refer your request to that Customer. Categories collected in the last 12 months: identifiers; commercial information; internet activity; audio and electronic information (call recordings); professional information; inferences (AI scores). [CONFIRM WITH COUNSEL]

Residents of other states with comprehensive privacy laws may have similar rights. [COUNSEL: ADD STATE-SPECIFIC LANGUAGE AS NEEDED]

8. Children

The Services are for businesses and are not directed to children under 16. We do not knowingly collect children's personal information.

9. International transfers

[DESCRIBE WHERE DATA IS STORED AND ANY TRANSFER MECHANISMS, OR STATE THE SERVICE IS US-ONLY]

10. Changes

We may update this policy and will post the updated version with a new effective date. [DESCRIBE NOTICE FOR MATERIAL CHANGES]

11. Contact

[LEGAL ENTITY NAME]
[MAILING ADDRESS]
[CONTACT EMAIL]