This Data Policy ("Policy") explains how Castiglia AI, owned and operated by Anthony Castiglia, collects, processes, stores, protects, uses, and handles data in connection with our Services.
This Policy is intended to clearly explain how customer data is handled and to affirm Castiglia AI's core data commitment:
Your data stays yours. Castiglia AI does not sell customer data.
Purpose of This Policy
The purpose of this Policy is to explain:
- What data may be collected or processed through the Services
- Who owns customer data
- How Castiglia AI uses customer data
- How Castiglia AI protects customer data
- When customer data may be shared
- How long customer data may be retained
- How customer data may be deleted, exported, or restricted
- How customer data may or may not be used in connection with AI systems
Key Data Principles
2.1 — Customer Ownership
As between Castiglia AI and the customer, customers retain ownership of their Customer Data.
2.2 — No Sale of Customer Data
Castiglia AI does not sell Customer Data. Castiglia AI does not sell customer contact lists, CRM records, call recordings, transcripts, prompts, uploaded files, customer communications, or business information.
2.3 — Limited Use
Castiglia AI uses Customer Data only as necessary to provide, secure, support, maintain, troubleshoot, and improve the Services, as described in this Policy.
2.4 — No Customer-Specific AI Training Without Authorization
Unless expressly authorized by the customer in writing, Castiglia AI does not use customer-specific Customer Data to train proprietary AI models.
2.5 — Customer Responsibility
Customers are responsible for ensuring that the data they submit to the Services is collected, used, disclosed, transmitted, and processed lawfully.
Definitions
3.1 — Customer Data
"Customer Data" means data, content, materials, records, files, prompts, scripts, contact lists, CRM records, leads, recordings, transcripts, call logs, messages, emails, knowledge base materials, uploaded documents, configurations, workflows, and other information submitted to, uploaded to, generated through, or processed by the Services on behalf of a customer. This includes contact lists, leads and prospect data, CRM records, call recordings, call transcripts, SMS and email content, AI prompts, assistant instructions, knowledge base documents, uploaded files, appointment data, and automation configurations.
3.2 — Personal Information
"Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual, household, or business contact, depending on applicable law.
3.3 — Usage Data
"Usage Data" means technical, operational, diagnostic, and performance information related to use of the Services, including log data, system performance data, feature usage, API usage, workflow activity, error reports, date and time stamps, device and browser information, interaction patterns, and usage volume.
3.4 — Aggregated or Anonymized Data
"Aggregated Data" or "Anonymized Data" means information that has been combined, summarized, de-identified, anonymized, or otherwise processed so that it does not identify a specific customer, individual, contact, lead, business, account, or communication recipient.
Customer Ownership of Data
As between you and Castiglia AI, you retain ownership of your Customer Data. Castiglia AI does not claim ownership of your Customer Data.
You are responsible for the accuracy, legality, source, consents associated with, permissions required to use, and content and configuration of your Customer Data, as well as any communications sent, received, generated, or processed using Customer Data.
Castiglia AI Ownership of Platform Technology
Castiglia AI retains all right, title, and interest in and to its technology, platform, software, systems, workflows, templates, configurations, intellectual property, and related materials. This includes software, source code, platform architecture, APIs, integrations, AI orchestration systems, prompt frameworks created by Castiglia AI, workflow and automation templates, call flow structures, system instructions, analytics tools, dashboards, documentation, business processes, service methodologies, improvements, enhancements, modifications, derivative works, know-how, and trademarks and branding.
Except as expressly stated in a written agreement, your use of the Services does not transfer ownership of Castiglia AI technology, intellectual property, workflows, templates, software, or systems to you.
Data We May Collect or Process
6.1 — Account and Business Data
We may collect name, business name, email address, phone number, mailing address, billing contact information, account credentials, authorized user information, business website, industry, service plan, onboarding information, and support communications.
6.2 — Customer Data Submitted to the Services
We may process Customer Data that you upload, submit, configure, connect, transmit, or generate through the Services, including contact lists, leads, CRM records, customer and prospect information, uploaded documents, knowledge base materials, prompts, scripts, call flows, workflow instructions, assistant configurations, call recordings, call transcripts, chat messages, SMS and email content, calendar information, appointment data, and integration data.
6.3 — Communications Data
If you use voice, SMS, email, chat, or other communication features, we may process phone numbers, call metadata, call recordings and transcripts, call summaries, voicemail data, SMS and email content, chat logs, communication timestamps, disposition data, appointment outcomes, and assistant and recipient responses.
6.4 — Technical and Usage Data
We may collect IP addresses, device information, browser information, operating system, log files, error reports, API calls, workflow activity, assistant performance data, feature usage, session data, diagnostic information, and system events.
6.5 — Integration Data
If you connect third-party platforms to the Services, we may process information from or to those platforms as necessary to provide the Services, including data from CRM platforms, marketing automation platforms, email systems, SMS providers, telephony providers, calendar tools, payment processors, analytics tools, and customer support tools.
How Castiglia AI Uses Customer Data
7.1 — Providing the Services
We may use Customer Data to configure AI assistants, operate automations, process calls and communications, generate transcripts and summaries, execute integrations, sync data with connected platforms, route communications, schedule appointments, create reports, and deliver requested functionality.
7.2 — Support and Troubleshooting
We may use Customer Data to diagnose technical issues, resolve support requests, investigate errors, test workflows, review failed automations, identify configuration problems, restore functionality, and improve service reliability.
7.3 — Security and Abuse Prevention
We may use Customer Data and Usage Data to detect unauthorized access, prevent fraud and abuse, detect spam or unlawful activity, investigate policy violations, enforce our Terms of Service, and protect the Services, customers, contacts, recipients, third-party providers, and the public.
7.4–7.5 — Billing, Legal Compliance
We may use data to manage subscriptions, process payments, track usage-based charges, generate invoices, resolve billing issues, enforce payment obligations, support collections and dispute resolution, comply with applicable laws, respond to legal process, defend claims, and meet accounting, tax, regulatory, and audit obligations.
7.6 — Service Improvement
We may use data to maintain, improve, and develop the Services. Where possible and appropriate, service improvement uses will rely on Aggregated Data, Anonymized Data, de-identified information, operational metrics, or Usage Data rather than customer-specific Customer Data.
No Sale of Customer Data
Castiglia AI does not sell Customer Data. Castiglia AI does not sell, rent, broker, trade, or monetize:
- Customer contact lists or lead lists
- Prospect data or CRM records
- Customer records or call recordings
- Call transcripts, SMS messages, or email messages
- Chat content, AI prompts, or assistant instructions
- Uploaded documents or knowledge base content
- Customer business information or communications
- Customer account data
Castiglia AI does not share Customer Data with third parties for third-party advertising or data brokerage.
AI Training and Model Improvement
9.1 — No Customer-Specific Training Without Authorization
Unless expressly authorized by the customer in writing, Castiglia AI does not use customer-specific Customer Data to train proprietary AI models. This includes customer-specific call recordings, call transcripts, customer prompts, assistant instructions, contact lists, CRM records, lead data, uploaded documents, knowledge bases, customer communications, business workflows, and industry-specific records.
9.2 — Aggregated and Anonymized Improvement
Castiglia AI may use Aggregated Data, Anonymized Data, de-identified information, Usage Data, performance metrics, and operational analytics to improve the Services, improve reliability, security and performance, develop new features, identify usage trends, troubleshoot errors, improve platform functionality, evaluate system performance, and improve customer support. Such data will not reasonably identify a specific customer, individual, lead, contact, call recipient, or business.
9.3 — Third-Party AI Providers
Some Services may rely on third-party AI providers or infrastructure providers. Customer Data may be transmitted to third-party providers as necessary to provide requested Services, such as generating responses, processing voice or text, creating transcripts, analyzing communications, or completing automations. Castiglia AI will use commercially reasonable efforts to work with reputable providers and configure services consistent with our data commitments where commercially available. However, third-party providers may have their own terms, privacy practices, technical limitations, processing rules, and retention practices.
9.4 — Customer Responsibility for Sensitive Data
You are responsible for determining whether Customer Data includes sensitive, confidential, protected, or regulated information. Unless expressly agreed in writing, you may not submit or process through the Services protected health information, full financial account numbers, payment card data, government identification numbers, highly sensitive personal information, children's data, biometric identifiers, or data subject to special contractual or regulatory restrictions.
Data Sharing and Disclosure
Castiglia AI may share Customer Data only as described in this Policy, the Privacy Policy, the Terms of Service, or an applicable written agreement, including with service providers, through customer-directed integrations, for legal and safety disclosures, and in connection with business transfers. Service providers are expected to use data only as necessary to provide services to Castiglia AI or the customer.
Data Security
Castiglia AI uses commercially reasonable administrative, technical, and organizational measures designed to protect data from unauthorized access, disclosure, alteration, destruction, loss, misuse, or compromise. These measures may include access controls, role-based permissions, authentication controls, encryption in transit where supported, secure infrastructure providers, monitoring and logging, internal access restrictions, vendor review, security best practices, and backup and recovery practices.
However, no internet-based or electronic system can be guaranteed to be completely secure. Castiglia AI does not guarantee absolute security. You are responsible for securing your devices, networks, accounts, credentials, passwords, API keys, connected platforms, authorized users, internal systems, and your own data handling practices.
Data Retention
Castiglia AI retains data for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, enforce agreements, maintain business records, and protect the Services. Retention periods may depend on account status, service plan, type of data, legal obligations, billing and accounting requirements, security requirements, backup practices, dispute resolution needs, and operational requirements.
12.1–12.4 — Retention Scenarios
While your account is active, Castiglia AI may retain Customer Data as necessary to provide the Services. After termination or cancellation, Castiglia AI may delete, archive, anonymize, or retain Customer Data in accordance with applicable policies and obligations. Deleted data may remain in backups until overwritten according to standard retention cycles. Castiglia AI may retain data for longer periods if necessary to comply with legal obligations, preserve evidence, resolve disputes, or protect legal rights.
Data Deletion and Export
Customers may request deletion or export of Customer Data by contacting Castiglia AI. Requests may be subject to account verification, technical limitations, applicable law, billing status, security requirements, backup limitations, third-party provider limitations, fees for custom export or recovery services, and the terms of any applicable written agreement. Castiglia AI is not required to provide data exports in a custom format unless expressly agreed in writing. Castiglia AI is not responsible for deleting, exporting, or modifying data stored in third-party platforms outside Castiglia AI's control.
Customer Compliance Responsibilities
Customers are solely responsible for ensuring that their use of data through the Services complies with all applicable laws, regulations, ordinances, and governmental requirements. Customers are responsible for lawfully collecting data, obtaining required consents, providing required privacy notices, maintaining lawful contact lists, honoring opt-outs and revocations, complying with Do Not Call requirements, call recording laws, AI disclosure laws, privacy and data protection laws, industry-specific regulations, and ensuring that Customer Data may lawfully be provided to Castiglia AI. Castiglia AI does not provide legal advice.
Regulated and Sensitive Data
Unless expressly agreed in writing, Castiglia AI is not intended to store or process highly regulated or sensitive data requiring specialized compliance obligations. You may not use the Services to process protected health information, payment card data, full bank account numbers, Social Security numbers, government identification numbers, biometric data, children's data, precise geolocation data, sensitive financial or legal information, or data subject to special regulatory restrictions unless your use is expressly permitted by Castiglia AI. If you submit such data without authorization, you are solely responsible for all consequences.
International Data Transfers
Castiglia AI is based in the United States. Data may be transferred to, processed in, stored in, or accessed from the United States or other jurisdictions where Castiglia AI or its service providers operate. If you access or use the Services from outside the United States, you are responsible for determining whether your use complies with applicable cross-border data transfer laws.
Data Incidents
If Castiglia AI becomes aware of a security incident involving Customer Data under Castiglia AI's control, Castiglia AI will take reasonable steps to investigate and respond. Where required by law or applicable agreement, Castiglia AI will provide notice to affected customers. Customers are responsible for determining whether they have independent notice obligations to their customers, leads, contacts, communication recipients, regulators, or other third parties.
Changes to This Policy
Castiglia AI may update or modify this Policy from time to time. Changes will become effective upon posting to our website or otherwise making the updated Policy available, unless a later effective date is stated. Your continued use of the Services after changes become effective constitutes acceptance of the updated Policy.
Contact Information
For questions, concerns, or requests regarding this Data Policy or Castiglia AI's data practices, please contact: