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Two different relationships

Kluup handles personal data in two roles, and confusing them is how privacy policies go wrong. This page covers the first; the second has its own agreement.

Who the controller is

Kluup Limited, company number company number not yet supplied, registered office registered office not yet supplied. Data-protection enquiries go to data-protection contact not yet supplied; anything else to contact email not yet supplied.

What this website stores

No cookies. No analytics. No advertising or tracking pixels. No third-party scripts of any kind. The whole site is static HTML, one stylesheet, and about 1.7 KB of JavaScript that does two things: it switches the theme and it marks which page you are on in the navigation.

The one thing kept in your browser is your light-or-dark preference, stored under kluup.theme, only if you press the theme button. It never leaves your device, is not sent to us, and clearing your browser storage removes it. There is no cookie banner on this site because there is nothing to consent to.

The web server that answers your request necessarily sees your IP address and the page you asked for, as every web server does.

What an account holds

When you create a workspace or accept an invitation we hold:

• Your name and work email address, and a hashed password — never the password itself.
• The organisation you belong to and your role in it.
• Sign-in and session records.
• An audit record of which scored calls were read, by whom, and when. That record exists to protect the people being scored, and it is described in clause 8.2 of the data processing agreement.
• The organisation's billing ledger, if it is a paying customer.

We send service email only — verifying an address, resetting a password, accepting an invitation. There is no marketing list to be added to.

Call recordings, and the two people on them

Here we are the processor, not the controller, and the detail is in the data processing agreement. The two things worth repeating on a public page:

• The lead — the person who was called. We hold the identifier the customer's CRM uses for that person and nothing else about them. Records are keyed on that identifier and never on a name; there is deliberately no field for one.
• The rep — the person whose call is scored. Reps are named, because the scorecard is about them. That is exactly why clause 9 exists.

Transcription is ours and transcripts are never stored. From an integration we take the audio and nothing else, transcribe each channel on infrastructure we operate, hold the text in memory for the length of one analysis and never write it to disk. We never ingest a third party's transcript.

Who else touches it

Any change to this list is published, with notice before it takes effect. Transcription is not sub-processed — it runs on infrastructure we operate, which is the reason a CRM's transcript is never good enough for us.

We do not benchmark across customers. No data crosses a tenant boundary for any purpose, including our own improvement. Nothing is used to train, tune or evaluate anything for anybody but the customer it came from — which is also why Kluup has no industry benchmark to sell.

How long anything is kept

The retention sweep is scheduled and each run is recorded, so deletion can be proven by query rather than asserted in a paragraph. A customer can delete by contact, by rep or by whole organisation from inside the product, and each leaves no residue in the database, in storage or in the ledger — except the money, kept under an opaque reference for the period above.

Your rights

You can ask us for a copy of the personal data we hold about you, ask us to correct it, ask us to erase it, object to processing, ask for it in a portable form, and complain to a supervisory authority. Write to data-protection contact not yet supplied and we will answer within the time the law allows.

The supervisory authority you can complain to is supervisory authority and complaints address not yet settled.

Where a request concerns call data we hold for a customer, the customer is the controller and the request belongs to them; we assist them with it within the time the law allows them to respond, and we will tell you who to ask.

If you are a rep being scored

Your employer decides that your calls are recorded and scored, so your employer is the controller and your rights run against them. What Kluup guarantees, in every account, at no extra cost, and with no way for an employer to switch it off:

• You can see your own calls, your own scores, and the verbatim words behind each one.
• A score with no quote behind it is shown as unjudged, never as a number, and never quietly enters an average.
• You can dispute a scored call. The disagreement travels with the record, so anyone who reads that score later sees it. Only a manager can mark it resolved, and removing it entirely means deleting the call.
• You cannot see another rep's calls, quotes or scores, and nor can anyone see yours who is not entitled to.

Kluup neither makes nor recommends employment decisions. It produces scores, each traceable to the words that justified it, and a person reads them. If your employer uses a score in a review, a bonus, a promotion or a dismissal, that decision is theirs, and they are responsible for meaningful human involvement in it and for explaining it to you. The two rights above exist so that they can.

And the gate verdict describes the lead, not you. A call that reached nobody worth selling to is not a poor performance, and the product keeps the two numbers apart on purpose so that it cannot be read as one.

What we never do

• No voice-derived emotion or tone scoring. Ever, anywhere. Article 5(1)(f) of the EU AI Act prohibits inferring a person's emotions in the workplace and has been in force since February 2025. How a voice sounds is never scored — not its tone, not its pitch, not how loud it was — and Kluup never infers stress, frustration, enthusiasm or confidence from it, for any customer, in any jurisdiction. It is a product red line, not a setting. Scoring the content of what was said against a scorecard is not emotion inference, and nor are the turn-taking figures — question counts, longest monologue, talk ratio — which are counted from who spoke when: off the recording's own clock where we transcribed one, worked out from the transcript and labelled as such where there was none. Both are arithmetic over words and turns. The one acoustic thing we do read is a loudness trace drawn behind the call timeline for a person to look at; it reaches no score.
• We never take a CRM's transcript, and we never store one of our own.
• We never hold a lead's name; there is no field for it.
• Our staff do not read your calls, and there is no support path that needs to.
• We never sell personal data, and we run no advertising.

What is not settled yet

Published rather than hidden, for the same reason the security page publishes its open questions: you would find out eventually and you should find out from us.

• The EU AI Act classification is unassessed. Annex III treats AI used to evaluate workers as high-risk. Whether Kluup is a high-risk system for EU deployments, and in which role, has not yet been assessed by a practitioner. For a UK-only customer the Act does not apply. The prohibition that is already in force — workplace emotion inference — is a line the product was built never to go near.
• The data protection impact assessment is awaiting review and signature by a practitioner, and the data processing agreement derived from it is version 1.0 and with counsel.
• The hosting and object-storage providers are not yet named. Anthropic, which is the sub-processor that receives transcript text, is named above.
• Our identifier scan cannot see a name. Kluup scans its own storage for personal data by pattern, so it catches email addresses, phone numbers and postcodes and deliberately never catches a name — a name blacklist would destroy the data the product is built on. A clean run therefore means “no detectable identifiers”, not “no personal data”, and we will not describe it any other way.
• 13 legal facts this policy needs are still unknown and appear above as visible markers rather than as something plausible — including the supervisory authority, the transfer mechanism and how long account data is kept. The build that publishes this site fails while any of them is missing.

Contact and complaints

Kluup Limited, registered office registered office not yet supplied. Data-protection enquiries: data-protection contact not yet supplied. Anything else: contact email not yet supplied.

If we have not put something right, you can complain to supervisory authority and complaints address not yet settled. We notify a customer without undue delay after becoming aware of a personal data breach affecting their data, with what we know at the time and what we learn after.

We will publish any change to this policy here, and any change to the sub-processor list with notice before it takes effect.