Privacy Policy
Last updated: 20 October 2026
TrueHunch Inc. (together with its subsidiaries and affiliates – “TrueHunch”, “TrueHunch.ai”, “we”, “our” or “us”) is committed to making sure that the personal data we process is kept safe and used properly, and that our data practices are clearly explained to our customers, users and prospects.
This Privacy Policy applies to our website at www.TrueHunch.ai (the “Website”), the TrueHunch conversation-intelligence platform and its related applications (the “Platform”), and our related services (together with the Website and the Platform, the “Services”). By using our Services, you acknowledge that you have read and understood this Privacy Policy. Certain processing activities rely on your consent, which you can give or withdraw at any time. Other processing is necessary to provide our Services or to comply with legal obligations.
Our Services are intended for business use by adults. Please see Section 14 for information about children’s data.
1. Our Roles: Controller and Processor
- TrueHunch as data controller: We are the “data controller” (under the GDPR) or “business” (under the CCPA/CPRA) for Website, CRM & Prospect Data and for the Location Data described in Section 3. For that data we assume the responsibilities of a controller as set out in this Privacy Policy.
- TrueHunch as data processor: We are the “data processor” (or “service provider”) of Customer Data, which we process on behalf of our customer, who is the “data controller” of that data. Our Service Providers who process Customer Data on our behalf are “sub-processors”.
- Dual role for TrueHunch User Data: We are both a controller and a processor of TrueHunch User Data. We process it for our own purposes (described in Section 4) as an independent controller, while the portions of it that are included in Customer Data are processed on our customer’s behalf as a processor.
- Processing according to instructions: We process Customer Data strictly in accordance with our customer’s reasonable instructions and as set out in our Data Processing Addendum and other commercial agreements with that customer. The customer, as controller, is responsible for meeting the legal requirements that apply to controllers, such as establishing a legal basis for processing and responding to data subject requests about the data it controls.
- Customer responsibility: Each customer is solely responsible for giving adequate notice to its users and to the people whose data appears in Customer Data, including call participants, and for obtaining any approvals or consents required by applicable law. This includes informing call participants of, and obtaining consent to, call recording and analysis where the law requires it (for example, in jurisdictions with two-party or all-party consent rules).
2. Data We Collect
We collect and process the following categories of personal data:
- Customer Data: Our Services enable customers to record, transcribe, analyze and share the content of their sales and service communications, including phone calls, video conferences, email and other correspondence, together with their CRM records and customer contacts (“Customer Data”). From this content the Platform produces outputs such as intent, objections, sentiment, compliance flags, quality scores and recommended next actions. Customer Data typically relates to identifiable individuals, such as the customer’s sales and service representatives, prospects, customers and other people who take part in or are mentioned in communications, and may include voice recordings and transcripts. We process Customer Data strictly on our customers’ behalf.
- TrueHunch User Data: Personal data concerning users of our Platform, namely: account information (e-mail address and, when applicable, a hashed password); profile and contact information (name, title, team, company, e-mail address, phone number, and additional information or media submitted by users, their teammates or their organization); Platform usage information (connectivity, technical and aggregated usage data such as user agent, IP address, device data like type, OS, device ID, browser version, locale and language settings, activity logs and session recordings); Location Data (see Section 3); and direct interactions with us (including recordings and transcripts of calls and emails with us, for example for support, enablement and training).
- TrueHunch Website, CRM & Prospect Data: Personal data concerning our website visitors, customers and prospects, namely: Website usage information (connectivity, technical and aggregated usage data such as user agent, IP address, device data, locale and language settings, activity logs, session recordings, and the cookies and pixels installed or used on their device); customer account information (contact, contractual and billing details, including details of the customer’s account administrators, billing contacts and authorized signatories, and the customer’s needs and preferences); and information about customers and prospects (contact and business details, our communications with them including call and video recordings and analyses of them, and any needs, preferences, attributes and insights relevant to our engagement).
3. Location Data
When you accept our Platform Use Terms (the “Platform Terms”) and when you sign in to and use the Platform, we derive your approximate location from your IP address, for example your country, region and city (“Location Data”). We do not collect precise location such as GPS coordinates, and we do not track your movements. Location Data is personal data under the GDPR and similar laws, and we treat it accordingly.
What we record
- The date and time you accepted the Platform Terms, the version you accepted, your IP address and the approximate location derived from it, kept as evidence of your acceptance.
- Approximate location associated with sign-in and session events in the activity logs of your account.
Why we use it
- To keep a record that you accepted the Platform Terms, and to establish, exercise or defend legal claims.
- Authentication and security, for example to detect unusual sign-ins and prevent fraud or account takeover.
- To apply region-specific requirements and settings, such as data-residency, call-recording and compliance rules that vary by jurisdiction, and to set a default time zone and language.
- To produce aggregated, de-identified statistics about Platform use by region.
Legal basis
We rely on contractual necessity (to provide the Platform and to record that you accepted the Platform Terms), legitimate interests (security, fraud prevention, legal compliance and service improvement, which we have balanced against your rights, in part because the data is approximate) and, where applicable, legal obligation. Accepting the Platform Terms is how we form the contract with you and record that you did so. It is not a request for your consent to anything beyond what this Section describes. If we ever want to use location for a purpose that requires your consent, such as precise location or location-based marketing, we will ask you separately, you will be free to refuse, and you will be able to withdraw your consent at any time.
Sharing, retention and your choices
We use a Service Provider to convert IP addresses into approximate locations, and we store Location Data in the regions described in Section 6. We keep acceptance records for as long as your account is active and afterwards for the period needed to evidence acceptance and defend legal claims. Other Location Data in activity logs is kept only as long as needed for security and diagnostics and is then deleted or aggregated, in line with Section 7. You can object to this processing or ask for access, correction or deletion by contacting privacy@TrueHunch.ai (see Section 12). A VPN or proxy may make your approximate location inaccurate. Where location is necessary for security or legal compliance, objecting may mean we cannot provide the Platform to you.
4. How We Use Personal Data and Our Legal Bases
We process personal data in accordance with applicable data protection laws, including the GDPR, for the purposes below and on the legal bases shown:
- Providing, operating and improving our Services: contractual necessity; legitimate interests.
- Authentication and security: legitimate interests; contractual necessity.
- Customer support and service: contractual necessity; legitimate interests.
- Analytics and service optimization: legitimate interests; consent for non-essential cookies and similar technologies.
- Marketing and communication: legitimate interests for business-to-business contact; consent where the law requires it.
- Legal compliance, protecting our rights and keeping records of acceptance of our terms: legal obligation; legitimate interests.
Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before it. Where we process Customer Data as a processor, our customer determines the purposes and the legal basis.
5. AI Processing and Automated Decision-Making
The Platform uses artificial-intelligence models to transcribe and analyze communications and to generate insights such as intent, objections, sentiment, compliance flags, quality scores and recommended next actions. Where we use third-party AI model providers, they act as our sub-processors under written agreements that limit them to processing on our instructions. We do not use Customer Data to train AI models that are made available to other customers.
These outputs are decision-support insights for our customers. TrueHunch does not itself make decisions about individuals that produce legal or similarly significant effects. Customers decide how to use the outputs and, where outputs are used in connection with people’s employment or evaluation, they are responsible for ensuring appropriate human review and compliance with applicable law.
We may also use automated processing or profiling in limited circumstances, such as:
- For fraud prevention and security purposes, including location-based sign-in checks
- To personalize our Services and marketing communications
- To analyze customer interactions and improve our Services
If we ever make a decision based solely on automated processing that produces legal or similarly significant effects on you, we will tell you, give you meaningful information about the logic involved and its significance and consequences, apply suitable safeguards, and let you request human intervention, express your point of view and contest the decision.
6. Data Location and International Transfers
We and our authorized Service Providers maintain, store and process personal data in the United States of America and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as required by law.
For transfers of personal data from the EEA and the UK to the United States or other countries that may not have an adequate level of data protection as determined by those jurisdictions, we implement appropriate safeguards, including:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Additional technical and organizational measures to ensure an adequate level of protection
7. Data Retention
We retain Customer Data strictly on our customers’ behalf, in accordance with their reasonable instructions.
We retain TrueHunch User Data and TrueHunch Website, CRM & Prospect Data for as long as is reasonably necessary:
- To maintain and expand our relationship and provide you with our Services and offerings;
- To comply with our legal and contractual obligations; or
- To protect ourselves from potential disputes (for example, as required by laws on log-keeping, records and bookkeeping, and to have proof and evidence of our relationship should legal issues arise after you stop using our Services),
all in accordance with our data retention policy. Except as required by applicable law or our specific agreements with you, we are not obligated to retain your personal data for any particular period, and we may securely delete it or restrict access to it at any time. If you have questions about our data retention policy, please contact us at privacy@TrueHunch.ai.
10. Communications
We send service-related communications necessary for the operation of our Services, and promotional communications that you can opt out of at any time.
- Service communications: We may contact you with important information about our Services.
- Promotional communications: We may also tell you about new features, additional offerings, events, special opportunities, or other information we think you will find valuable as our customer, user or prospect.
11. Data Security
We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including encryption, access controls and other security protocols. More detail is available in our Trust Center.
While we make efforts to protect your privacy and implement industry-standard security measures, we cannot guarantee that our Website, Platform or Services will be immune from wrongdoing, malfunctions, unlawful interception or access, or other forms of abuse and misuse.
12. Your Rights
Under the GDPR and similar data protection laws, you have the following rights regarding your personal data:
- Right of access: to know whether we process your personal data and to access it.
- Right to rectification: to request correction of inaccurate personal data.
- Right to erasure: to request deletion of your personal data in certain circumstances.
- Right to restrict processing: to request restriction of processing in certain circumstances.
- Right to data portability: to receive your personal data in a structured, commonly used, machine-readable format.
- Right to object: to object to processing based on legitimate interests and to direct marketing.
- Right to withdraw consent: to withdraw any consent you have given, at any time.
- Rights relating to automated decision-making: not to be subject to decisions based solely on automated processing that produce legal effects.
- Right to complain: to lodge a complaint with your local data protection supervisory authority.
To exercise these rights, please contact us at privacy@TrueHunch.ai. We will respond to all data subject rights requests within one month. This period may be extended by up to two further months where necessary, taking into account the complexity and number of requests. If your personal data is contained in Customer Data, we may refer your request to the relevant customer, who is the controller of that data.
US state privacy rights
Residents of California and certain other US states may have the right to know and access the personal information we hold about them, to request deletion or correction, to opt out of the sale or sharing of personal information, to limit the use of sensitive personal information, and not to be discriminated against for exercising these rights. We do not sell personal information. Approximate location derived from an IP address is not precise geolocation, and we do not use it to infer characteristics about you. We honour the Global Privacy Control signal as described in Section 9. To make a request, contact us at privacy@TrueHunch.ai.
13. Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:
- Notify the relevant supervisory authority without undue delay and, where required, within 72 hours of becoming aware of the breach
- Notify affected data subjects without undue delay where the breach is likely to result in a high risk to them
Where we act as a processor, we will notify the affected customer without undue delay so that they can meet their own obligations.
14. Children’s Data
Our Services are intended for business use by adults and are not designed to attract children. We do not knowingly collect personal data from children under the age of 16 and do not wish to do so.
If we learn that a person under the age of 16 is using the Website, Platform or Services, we will:
- Promptly attempt to prohibit and block such use
- Promptly delete any personal data we hold about that child
- Implement additional safeguards to prevent future unauthorized access
If you believe that we might have any data from or about a child under 16, please contact us by e-mail at privacy@TrueHunch.ai.
15. Changes to this Policy and Contact Details
- We may update this Privacy Policy from time to time by posting an updated version on our Website and changing the “Last updated” date above. If we make material changes, we will take reasonable steps to notify you.
- You may contact our Data Protection Officer at privacy@TrueHunch.ai.
- If you have comments or questions about this Privacy Policy, or concerns about personal data we hold about you, please contact us at privacy@TrueHunch.ai or info@TrueHunch.ai. If you are protected by the GDPR, you also have the right to lodge a complaint with a supervisory authority in your country.