Privacy Policy

1. Roles: Controller and Processor

As Data Controller. For data we collect directly — website visitors, leads, account and billing contacts — STRATEGIC DEALS SL acts as Data Controller.

As Data Processor. For the content customers upload or generate through the platform — call recordings, transcripts, performance analysis and related data — Performy acts solely as a Data Processor on behalf of the customer (or the customer's own client), who remains the Data Controller. Performy processes such data only under the customer's documented instructions and under a Data Processing Agreement (DPA), never for its own purposes.

2. Purpose of Processing

We process information to manage the commercial relationship, including:

• •Service Delivery: Execution of performance engineering contracts, AI video call analysis, and CRM automation.
• •Commercial Communications: Sending product updates and electronic offers.
• •Product Improvement: We improve our service using aggregated, anonymized usage metrics only. We do not use customer content (call recordings, transcripts or analysis) to train AI models.

3. Legal Basis and Retention

• •Contractual Execution: Processing is necessary for the performance of the service contract.
• •Retention (our own data): Commercial and billing data is kept for the duration of the relationship and five (5) years thereafter to meet legal obligations.
• •Retention (customer content): Call recordings, transcripts and analysis processed on behalf of customers are deleted within a maximum of thirty (30) days after account termination, unless law requires otherwise. Customers may export their data at any time.

4. Recipients, Subprocessors and Data Sovereignty

Data is stored on servers within the European Union (AWS Ireland, eu-west-1), in compliance with GDPR. We do not sell data or transfer it to third parties except under legal obligation or to the controlled subprocessors required to deliver the service:

We impose equivalent data-protection obligations on every subprocessor and will notify customers of any material change to this list. International transfers are covered by valid mechanisms (e.g. Standard Contractual Clauses).

5. Your Rights

You may exercise your rights of Access, Rectification, Erasure, Limitation, Objection, and Portability by contacting legal@performy.ai. We guarantee human oversight in performance analysis.