Data processing agreement for the Enterprise plan

Version: dpa-2026-10-18 · Version date: 18 October 2026

1. What this agreement is

1.1 This agreement is part of the Enterprise plan contract. It is accepted in the same checkbox on the secure payment page, and its version is recorded with the version of the contract. In any conflict on the processing of personal data, this agreement prevails.

1.2 For the data in clause 2, the organization is the controller and Telfluent LTD, company number 517416798, is the holder: an outside party that processes the data for the organization.

1.3 For card-payment data, Airwallex and the acquirers it works with are independent controllers, as set out in the contract (clause 5.10) and in the privacy policy. That is not sub-processing of call data.

2. What is processed for the organization

2.1 Telfluent processes for the organization only the following data, and only in order to provide the Service:

- The content of the call (voice and words): live translation. It is not kept.

- The call record: the phone that called, the number dialled, the time and the number of minutes.

- Names, phones, language and voice of workers, arms and arm managers.

- The account change log: what was done and when.

- An update address, if you added one, and the types of updates you chose for it.

2.2 Nothing said in an interpreted call is kept: neither as audio nor as text.

3. Provider categories

3.1 To provide the Service Telfluent works with providers in these categories only: hosting and backups; speech recognition, translation and voice; telephony and text messages; an automatic voice assistant; email; the hosting and distribution network of the website; card payments; identity verification; and tax invoices.

3.2 Providers are listed by category only. There are no names here, no countries and no numbered list. Names are not given to a customer, an authority or a government through the system. Giving a name is only by the hand of Telfluent's owner, case by case, to a competent authority or a court.

3.3 Airwallex is the only provider named in this agreement, because it is an independent controller of payment data, not a sub-processor of call data.

4. A new category

4.1 Before a new provider category receives data from clause 2, Telfluent sends notice by email to the account's address 14 days in advance.

5. A security incident

5.1 If Telfluent learns of a security incident that concerns the data in clause 2, it notifies the organization without delay, by email to the account's address.

6. Retention, deletion and the engine as it is

6.1 Call records and the change log are kept for 18 months and then deleted, until Telfluent's lawyer approves another period.

6.2 After an account is closed, billing ledgers, fiscal documents and the evidence trail are kept as far as billing law requires. There is no automatic deletion of them within 30 days of closure.

6.3 Some backups and logs of the hosting category are also outside the European Union.

6.4 A phone number that moved from one account to another remains linked for identifying the caller. This agreement does not promise that there is no linking by phone number.

7. Training

7.1 Nothing said is used to train models at Telfluent.

8. The binding version

8.1 The Hebrew version of this agreement is the binding version. The versions in the other languages are a translation for your convenience only.

8.2 Version label: dpa-2026-10-18.