Privacy Policy

1. Introduction

CallClimax ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered realtime voice-call platform and related services.

CallClimax operates under Spanish law and complies with the European Union General Data Protection Regulation (GDPR). By using our services, you consent to the data practices described in this policy.

Please read this Privacy Policy carefully. If you do not agree with the terms of this privacy policy, please do not access or use our services.

2. Information We Collect

We collect information that you provide directly to us, as well as information automatically collected when you use our services.

2.1 Account Information

• Email Address: Provided by you or obtained through Google or Patreon OAuth authentication
• OAuth Identifiers: Google user ID and/or Patreon user ID used for authentication
• Profile Preferences: Orientation, your saved name and gender used by your companions
• Payment Information: Billing and subscription data processed by our payment provider, including amounts and payment history

2.2 Companions and Call Data

• Companion Details: The name, voice, language, identity, and tags (physical, personality, kinship, kinks) you choose for each companion
• Your Name and Gender: What your companion calls you and how they address you
• Greetings: The opening line generated for each companion
• Memory: A rolling summary of your conversations and durable facts you ask your companion to remember, stored on your companion
• Call Logs: Structured logs of each call (timestamps, transcript, technical events) stored securely to keep the service working and for debugging
• Microphone Audio: Your live mic audio is streamed and transcribed in real time by our speech-recognition provider so your companion can hear you; it is not stored as a recording

2.3 Usage Data

• Call History: Which companions you call, call durations, and connection times
• Minutes Used: Records of connection time consumed and remaining balance
• Free-Call Usage: An IP-based counter used to enforce the free-call allowance
• Session Information: Login times, session duration, and authentication events
• Error Logs: Technical error messages and diagnostic information when a call fails

2.4 Technical Information

• IP Addresses: Your internet protocol address for security, fraud prevention, and free-call limits
• Browser Information: Browser type, version, and user agent string
• Device Information: Device type, operating system, and screen resolution
• Cookies and Session Data: Session cookies for maintaining login state
• Referral Source: The website or source that directed you to CallClimax

2.5 Communications

• Support Inquiries: Any messages, questions, or requests you send to hello@callclimax.com
• Feedback: Survey responses, feature requests, or other feedback you provide

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Service Delivery

• Run your live calls: transcribe your speech, generate your companion's replies, and synthesize their voice in real time
• Authenticate your account and verify your supporter status
• Allocate and manage your minute balance based on connection time
• Store and deliver voice previews and call logs
• Persist your companions and their memory so they remember you between calls

3.2 Service Improvement

• Analyze usage patterns to improve call quality and user experience
• Identify and fix technical issues, bugs, and performance problems
• Develop new features and enhance existing functionality
• Test and refine our speech-recognition and text-to-speech technology

3.3 Content Moderation

• Screen the tags, names, and descriptions you give your companions to enforce our Terms of Service
• Detect and prevent prohibited content as defined in our content policies
• Investigate reports of policy violations or abusive behavior
• Maintain the safety and integrity of our platform

3.4 Communications

• Send service-related notifications about your account, minutes, or calls
• Respond to your support inquiries and customer service requests
• Notify you of important changes to our Terms of Service or Privacy Policy

3.5 Security and Fraud Prevention

• Monitor for fraudulent activity, unauthorized access, or security threats
• Detect and prevent abuse of the free-call allowance
• Verify payment and subscription information
• Protect against spam, phishing, and other malicious activities

3.6 Legal Compliance

• Comply with applicable laws, regulations, and legal processes
• Respond to law enforcement requests and court orders
• Enforce our Terms of Service and protect our legal rights
• Investigate and report illegal content as required by law

4. How We Share Your Information

We do not sell, rent, or trade your personal information. We share your information only in the limited circumstances described below:

4.1 Third-Party Service Providers

We share information with third-party service providers that perform services on our behalf:

• Payment Processing: Subscriptions and top-ups are processed by our payment provider, which handles billing and payment data on our behalf
• AI Processing: We use third-party AI services for speech recognition, response generation, and text-to-speech synthesis. Your live microphone audio and conversation context are processed by these services in real time to run your call and are not stored as recordings
• Patreon: User authentication and legacy supporter status. Patreon's privacy policy governs their collection and use of your information.
• Google: User authentication through Google Sign-In. Google's privacy policy governs your Google account.
• Cloudflare R2: We store voice previews and call logs on Cloudflare's R2 storage infrastructure and deliver content through their CDN.
• Database Hosting: We use a managed database hosting provider, which stores your account information, companions, and call metadata.
• Hosting Infrastructure: We use a managed hosting provider for application hosting, which processes your requests and handles server-side operations.

These service providers are contractually obligated to use your information only for the purposes of providing services to CallClimax and are required to maintain appropriate security measures.

4.2 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Valid legal processes such as court orders, subpoenas, or search warrants
• Law enforcement requests, including investigations of illegal activity
• National security or public safety requirements
• Obligations to report child sexual abuse material (CSAM) to appropriate authorities
• Compliance with Spanish, European Union, or international regulations

4.3 Business Transfers

If CallClimax is involved in a merger, acquisition, sale of assets, bankruptcy, or other business transaction, your information may be transferred as part of that transaction. We will notify you via email or prominent notice on our website before your information becomes subject to a different privacy policy.

4.4 With Your Consent

We may share your information for purposes not described in this Privacy Policy if we obtain your explicit consent to do so.

4.5 What We Do Not Share

We explicitly do not:

• Sell your personal information or call content to third parties
• Share your conversations with advertising networks
• Publicly disclose your call history or companion data
• Provide your information to data brokers or analytics companies
• Link your identity to specific calls in any public context

5. Call Privacy and Confidentiality

We understand the deeply personal and sensitive nature of your calls. CallClimax is committed to maintaining the privacy and confidentiality of your activity:

• Private by Default: Your companions and calls are private and associated only with your account
• No Public Sharing: We never publicly display, sell, or distribute your companions or call logs without your explicit consent
• Secure Storage: Call logs and voice previews are stored securely with access controls limiting retrieval to authenticated users
• No Audio Recordings: Your live microphone audio is transcribed in real time for the call and is not stored as a recording
• Moderation Privacy: Content screening is conducted confidentially by automated systems and, when necessary, authorized personnel under strict confidentiality obligations
• No Marketing Use: We do not use your email address for marketing or promotional purposes without your opt-in consent
• Identity Protection: We never publicly associate your identity with specific calls, even in aggregate statistics or case studies

6. Data Retention

We retain your information for as long as necessary to provide our services and fulfill the purposes described in this Privacy Policy.

6.1 Active Accounts

For active accounts with an ongoing subscription:

• Account information is retained indefinitely while your account remains active
• Your companions and their memory are stored indefinitely while your account is active
• Call history and metadata are retained for the lifetime of your account
• Usage logs and minute history are maintained for billing and support purposes

6.2 Inactive Accounts

If your subscription ends or your account becomes inactive:

• Account data is retained for 180 days to allow for potential reactivation
• Call logs may be deleted after 90 days of inactivity to reduce storage costs
• You may request immediate deletion of your account and all associated data

6.3 Deleted Accounts

When you request account deletion:

• Personal information and account data are permanently deleted within 30 days
• Your companions and their memory are removed from our servers
• Call logs are removed from our storage
• Backup systems may retain data for up to 60 additional days before permanent deletion

6.4 Legal Retention

Notwithstanding the above, we may retain certain information if required by law or for legitimate business purposes, including:

• Financial records for tax and accounting compliance (7 years under Spanish law)
• Records subject to legal holds, investigations, or pending litigation
• Information necessary to enforce our Terms of Service or protect our legal rights
• De-identified or aggregated data that cannot be used to identify you personally

7. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

7.1 Security Measures

• Encryption in Transit: All data transmitted between your device and our servers is encrypted using HTTPS/TLS protocols
• Encryption at Rest: Sensitive data stored in our database is encrypted at rest
• Access Controls: Limited employee access to user data, restricted to authorized personnel for support and moderation purposes
• Secure Authentication: OAuth 2.0 integration with Google and Patreon for secure user authentication
• Session Management: Database-backed session storage with secure cookies and session expiration
• Infrastructure Security: Cloud hosting on secure infrastructure with firewalls, intrusion detection, and regular security updates

7.2 Security Limitations

While we implement robust security measures, please be aware that:

• No method of transmission over the internet is completely secure
• No system of electronic storage is absolutely impenetrable
• You are responsible for protecting your account credentials
• We cannot guarantee the security of information transmitted through unsecured networks

7.3 Breach Notification

In the event of a data breach that affects your personal information, we will:

• Notify you via email within 72 hours of becoming aware of the breach, as required by GDPR
• Describe the nature and extent of the breach
• Explain the potential consequences and steps we are taking to address the breach
• Provide recommendations for protecting your information
• Notify relevant supervisory authorities as required by law

8. Your Rights Under GDPR

As CallClimax operates under European Union law, you have the following rights regarding your personal data under the General Data Protection Regulation (GDPR):

8.1 Right of Access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of your personal information. This includes:

• All account information and profile data
• Your companions and their memory
• Minute usage and payment records
• Any other personal data we hold about you

8.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data. You can:

• Update your profile information in your account settings
• Request corrections to any inaccurate account data by contacting hello@callclimax.com

8.3 Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal data when:

• The data is no longer necessary for the purposes for which it was collected
• You withdraw consent and there is no other legal basis for processing
• You object to processing and there are no overriding legitimate grounds
• The data has been unlawfully processed

To exercise this right, contact hello@callclimax.com with your deletion request. We will process requests within 30 days.

8.4 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format. You may request:

• Export of your account information in JSON format
• Export of your companions and their memory
• Copy of your call history and metadata

8.5 Right to Restriction of Processing

You have the right to request restriction of processing your personal data when:

• You contest the accuracy of the data, pending verification
• Processing is unlawful but you prefer restriction over deletion
• We no longer need the data but you need it for legal claims
• You have objected to processing, pending verification of our legitimate grounds

8.6 Right to Object

You have the right to object to processing of your personal data based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

8.7 Rights Related to Automated Decision-Making

CallClimax uses AI to generate companion responses but does not use automated decision-making for account management without human oversight. You have the right to:

• Obtain human review of automated moderation decisions
• Express your point of view regarding automated decisions
• Contest decisions made solely by automated means

8.8 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email: hello@callclimax.com

We will respond to your request within 30 days. In complex cases, we may extend this period by an additional 60 days and will notify you of the extension. We may request additional information to verify your identity before processing your request.

8.9 Right to Lodge a Complaint

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with your local data protection authority or the Spanish Data Protection Agency (Agencia Española de Protección de Datos - AEPD).

9. International Data Transfers

CallClimax is based in Spain and operates within the European Union. However, some of our service providers are located outside the EU:

9.1 Data Storage and Processing Locations

• Database: Our database may store data in distributed locations including EU and non-EU regions
• Call Logs and Voice Previews: Stored in data centers globally, with primary storage in EU regions
• AI Processing: Our AI processing providers may handle call data in regions that include the US and EU
• Application Hosting: Hosting servers may be located in EU or US regions

9.2 Transfer Safeguards

When we transfer your personal data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data Processing Agreements with third-party service providers
• Adequacy decisions by the European Commission where applicable
• Binding Corporate Rules for multinational service providers

9.3 User Acknowledgment

By using CallClimax, you acknowledge and consent to the transfer of your personal data to countries outside the EEA for the purposes described in this Privacy Policy, subject to the safeguards outlined above.

10. Cookies and Tracking Technologies

10.1 Cookies We Use

CallClimax uses cookies and similar tracking technologies to maintain functionality and improve your experience:

• Session Cookies (Essential): Required for user authentication and maintaining your login state. These cookies are stored in our database and expire when you close your browser or log out
• Language Cookie: Remembers your preferred interface language
• OAuth Cookies: Set by Google or Patreon during the OAuth authentication process to verify your identity
• Cloudflare Cookies: Set by Cloudflare CDN for security, performance optimization, and DDoS protection

10.2 Third-Party Cookies

Our third-party service providers may set their own cookies:

• Google: May set cookies during authentication
• Patreon: May set cookies during authentication and subscription verification
• Cloudflare: Sets cookies for CDN functionality and security features

10.3 Analytics and Tracking

We use privacy-friendly analytics (Plausible, self-hosted) to understand aggregate usage of our site, and we may use standard tag-based tracking (Google Tag Manager, Microsoft Clarity) to improve the product. These tools do not identify you personally and we never sell your data. We do not use third-party advertising trackers.

10.4 Managing Cookies

You can control cookies through your browser settings. However, please note that disabling cookies may impact functionality:

• Essential session cookies are required for login and authentication
• Blocking cookies will prevent you from accessing your account
• Most browsers allow you to refuse cookies or delete existing cookies

10.5 Do Not Track Signals

CallClimax does not currently respond to "Do Not Track" (DNT) browser signals, as there is no industry-wide standard for how to interpret DNT signals. We do not track users across third-party websites.

11. Children's Privacy

CallClimax is an adult-oriented platform strictly prohibited for use by anyone under the age of 18. We do not knowingly collect, maintain, or use personal information from children under 18 years of age.

11.1 Age Verification

By creating an account and using CallClimax, you represent and warrant that you are at least 18 years of age.

11.2 Parental Notice

If you are a parent or guardian and believe your child has provided personal information to CallClimax, please contact us immediately at hello@callclimax.com. We will promptly investigate and delete such information.

11.3 Discovery of Underage Users

If we discover or have reason to suspect that a user is under 18 years of age, we will:

• Immediately terminate the account
• Permanently delete all personal information and companions
• Take steps to prevent re-registration

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

12.1 Notification of Changes

When we make material changes to this Privacy Policy, we will notify you by:

• Sending an email notification to the address associated with your account (if available)
• Displaying a prominent notice on the CallClimax website
• Updating the "Last updated" date at the top of this Privacy Policy

12.2 Effective Date

Changes to this Privacy Policy will become effective 14 days after notification. Your continued use of CallClimax after the effective date constitutes acceptance of the updated Privacy Policy.

12.3 Objecting to Changes

If you do not agree to the updated Privacy Policy, you must stop using CallClimax and may request deletion of your account and all associated data by contacting hello@callclimax.com before the changes take effect.

12.4 Reviewing Changes

We encourage you to periodically review this Privacy Policy to stay informed about how we protect your information. The current version will always be available at callclimax.com/privacy.

13. California Privacy Rights (CCPA)

While CallClimax is based in Spain, we extend certain privacy rights to California residents in compliance with the California Consumer Privacy Act (CCPA).

13.1 California Residents' Rights

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

• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you
• Right to Delete: Request deletion of your personal information, subject to certain exceptions
• Right to Opt-Out: Opt out of the "sale" of personal information (note: CallClimax does not sell personal information)
• Right to Non-Discrimination: Not receive discriminatory treatment for exercising your privacy rights

13.2 Information We Collect (CCPA Categories)

• Identifiers: Email address, IP address, OAuth identifiers
• Commercial Information: Payment history, minute usage, call history
• Internet Activity: Browsing history on CallClimax, interaction with our services
• Audio/Visual Information: Live call audio (streamed for transcription) and voice previews
• Inferences: Preferences derived from your usage patterns and voice selections

13.3 Do We Sell Personal Information?

CallClimax does not sell personal information as defined by the CCPA. We do not exchange your personal data for monetary consideration with third parties.

13.4 Exercising CCPA Rights

To exercise your CCPA rights, contact us at hello@callclimax.com. We will verify your identity and respond within 45 days.

14. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: hello@callclimax.com

Response Time: We respond to privacy inquiries within 72 hours during business days and will address your request within 30 days as required by GDPR.

14.1 Data Protection Officer

For GDPR-related inquiries or to exercise your data protection rights, you may contact our data protection contact at the same email address: hello@callclimax.com

14.2 Supervisory Authority

If you are located in the European Union and have concerns about our data practices that we have not adequately addressed, you may contact your local data protection authority or:

Spanish Data Protection Agency (AEPD)
Website: www.aepd.es

15. Legal Basis for Processing (GDPR)

Under GDPR, we process your personal data based on the following legal grounds:

15.1 Contractual Necessity

Processing is necessary to perform our contract with you and provide CallClimax services, including:

• Authenticating your account through Google or Patreon
• Running your live calls with your companions
• Managing your minute balance and usage
• Storing your companions, their memory, and call logs

15.2 Legitimate Interests

Processing is necessary for our legitimate interests, including:

• Improving our services and developing new features
• Detecting and preventing fraud, abuse, and security threats
• Analyzing usage patterns to optimize performance
• Enforcing our Terms of Service

15.3 Legal Obligations

Processing is necessary to comply with legal obligations, including:

• Retaining financial records for tax compliance
• Responding to law enforcement requests
• Reporting illegal content as required by law
• Complying with data protection regulations

15.4 Consent

For certain processing activities, we rely on your explicit consent, including:

• Receiving promotional communications (opt-in required)
• Sharing information beyond what is described in this policy
• Processing sensitive personal data where required

You may withdraw consent at any time by contacting hello@callclimax.com, though this will not affect the lawfulness of processing based on consent before withdrawal.

16. Additional Disclosures

16.1 No Public User Directories

CallClimax does not maintain public user directories or profiles. Your account, companions, and calls are private and not searchable by other users.

16.2 Third-Party Links

Our website may contain links to third-party websites (such as Patreon). We are not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

16.3 User-Generated Content Warnings

While we take measures to protect your privacy, please be cautious about including personally identifiable information in your companion descriptions or conversations. CallClimax cannot guarantee the privacy of information you voluntarily share during a call.

16.4 Sensitive Personal Data

CallClimax does not intentionally collect sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) except as incidentally included in companion descriptions or conversations. If you include such information, it will be processed solely for the purpose of providing the service you requested.

16.5 Aggregated and De-Identified Data

We may create aggregated, de-identified, or anonymized data from your personal information. This data cannot be used to identify you personally and may be used for any purpose, including research, analytics, and service improvement.

17. Consent

By using CallClimax, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein. If you do not agree with this Privacy Policy, please do not use our services.