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A wall of archive binders labelled by hand, worn grey spines packed tight.
GDPR, hosting, retention

Compliance

Written for your data protection officer, not to reassure you.

This page exists to be forwarded as it is to the person in your organisation who will have to approve Konvoice. It contains tables, retention periods and names, and not one sentence along the lines of “security is our priority”.

Roles

Who is responsible for what.

The distinction is not legal pedantry: it determines who answers a subject access request from your employees or your customers.

You are the controller

You decide why you record calls, who has access, how long you keep them, and you inform your employees and the people they speak to. Konvoice gives you the settings to apply those decisions, not the decisions themselves.

We are the processor

We process your data on your instructions, within the limits of the data-processing agreement. We do not use it for our own purposes, we do not sell it, and we train no model with it.

Hosting

Where your data physically sits.

You choose the region when your company is created. It does not change afterwards without your written agreement, and no data is replicated outside the chosen region.

RegionLocationAvailable to
European UnionFrance and Germany, two availability zonesThe default for every customer
CanadaMontréal and TorontoOn request
West AfricaAbidjan, with regional fallbackOn request
Private cloudThe host and the country you nameOn quotation
Your own serversAt your premises, with no egress to the internetSovereign mode
A distinction that matters An international phone call necessarily transits the networks of the carriers it crosses. The choice of region applies to the data we hold — configuration, logs, recordings, transcripts — and not to the physical path of a conversation to somebody abroad. No supplier can promise otherwise without lying.
Two people at a table, one filling in a form with a pen, papers spread out in front of them. What you sign

The data-processing agreement

The commitments on this page are in the contract, not only on it.

A compliance page promising what the contract does not say is a communications page. Every statement here has a signed counterpart — the list of sub-processors, the hosting location, the retention periods and the right to leave are annexes, not intentions.

  • Sub-processor annex — by name, with prior notification of any addition.
  • Guaranteed location — the European Union, at a named host.
  • Configurable retention — yours, with a contractual maximum and a verifiable purge.
  • The right to leave — full export of your data and your recordings, in a documented format.

Retention periods

How long each piece of data is kept.

The values below are the defaults. All of them can be changed by your administrator, up or down, company by company and queue by queue.

DataDefaultAdjustableDeletion
Call log and metadata24 months3 to 120 monthsAutomatic at expiry
Audio recordings6 months1 to 60 monthsAutomatic, audio and derivatives
Transcripts and summariesThe associated recording’s periodCan be independentFollow the recording
Voicemails3 months after being playedYesAutomatic
Audit log36 monthsMinimum 12 monthsNot modifiable before expiry
Billing data10 yearsLegal obligationAt the statutory expiry
User accountsThe term of the contractYes30 days after deletion
Backups35 days rolling7 to 90 daysAutomatic rotation

A requested deletion propagates to backups as they rotate, within a maximum equal to the backup retention period. We write this down because most suppliers omit it.

Sub-processors

The named list, kept up to date.

Every addition is notified to customers thirty days before it goes live, with a right of objection written into the contract.

Sub-processorRoleProcessing regionData concerned
Certified European hostCompute and storage infrastructureFrance, GermanyAll platform data
Telecommunications carriersRouting calls and SMSDepending on the destination calledCalling and called numbers, duration
Transcription supplierTranscription and summaries (Naya)European UnionAudio of recorded calls, if Naya is enabled
Transactional email serviceNotifications, voicemail by emailEuropean UnionEmail addresses, notification content
Support and monitoringTechnical logs and alertsEuropean UnionTechnical logs, with no conversation content

The contractual version of this register names each company, with its registered name, its country of establishment and the legal basis for any transfer. Ask for it

Labelled archive boxes on shelves in a wood-panelled room.

Keeping a recording longer than necessary is not caution. It is a breach.

The period is yours, and the purge is verifiable

Your obligations, our tools

What Konvoice gives you in order to comply.

Recording a call is processing personal data. Doing it properly requires four things, and they are in the product.

Informing people

An announcement played automatically to the caller, configurable by country and by language, with proof it was played in the log.

Right of access

A complete export of the data relating to a person — calls, recordings, transcripts — in a readable format, from the console.

Right to erasure

Deletion of a person and everything attached to them, with a report of what was deleted and what is retained under a legal obligation.

Record of processing

We supply the standard “business telephony” processing record your DPO can take and adapt, rather than drafting it from nothing.

Exit

What you take with you the day you leave.

An exit clause that does not say what is returned, in what format and within what time protects nobody.

  • Your numbers — outbound porting to the carrier of your choice, at no charge and with no extended notice condition.
  • Your recordings — a full export in standard audio files, with the index file linking each file to its call.
  • Your history — call logs, transcripts, notes and labels in open formats.
  • Your contacts and your configuration — directory, queues, hours and routing rules, in a readable format that documents what you will have to rebuild elsewhere.
  • Your devices — a full inventory with MAC addresses, so your next supplier takes over the estate without rediscovering it.
  • Timing — the export supplied within fifteen working days of the request, and the data deleted from our systems thirty days after the end of the contract, unless a legal obligation says otherwise.

Compliance questions

Do you have a standard data-processing agreement?
Yes, compliant with Article 28 of the GDPR, with the European Commission’s standard contractual clauses annexed for transfers outside the Union. We send it to you before signing, not at renewal.
Are we obliged to record calls?
No. Recording is off by default and stays optional, including on plans that include it. Some organisations record only a few queues, others none at all.
Does the GDPR oblige us to inform the caller?
You must inform them, yes, and in some cases obtain their consent. The rules vary by country and by purpose — training an agent and evidencing a transaction are not the same regime. Konvoice allows a different announcement per country and per queue; the wording is a matter for your legal counsel.
How do you respond to a judicial order?
We check its validity, we limit disclosure to its strict scope, and we inform you unless the law forbids us to. The number of requests received and honoured is published every year.
What happens in the event of a data breach?
We notify you without undue delay and at the latest within 48 hours of becoming aware of it, with the nature of the incident, the categories of data concerned and the measures taken. That deadline is contractual, which leaves you time to meet your own 72 hours.

Your DPO has questions? They will get written answers.

We answer compliance questionnaires with dated commitments and an identifiable person behind every answer.

This page is a summary for information. The contractual commitments are in the service agreement and its data-processing annex.