GDPR & Data Processing
Last updated: September 18, 2026 · Effective: September 21, 2026
1. Scope
This page explains how VM Hunter meets the EU General Data Protection Regulation (GDPR), the UK GDPR and the Swiss FADP, and sets out the data processing terms that apply when you send us personal data. It supplements the Privacy Policy and forms part of the Terms of Service.
2. Our roles
| Data | Our role | Who decides purposes |
|---|---|---|
| Your account, billing, sign-in logs, support messages, website analytics | Controller | VM Hunter |
| Call audio samples, transcripts, results and call identifiers your dialer sends us | Processor | You, our customer (the controller) |
3. Your rights as a data subject
Where we are the controller, you have the right to:
- Access the personal data we hold about you and receive a copy.
- Rectification of inaccurate or incomplete data. You can edit most of it in your Profile.
- Erasure where we no longer need the data or you withdraw consent.
- Restriction of processing in certain circumstances.
- Portability: call logs can be exported as CSV from the portal; other data on request.
- Object to processing based on legitimate interests, and to direct marketing at any time.
- Withdraw consent for analytics cookies or marketing email at any time.
- Complain to your local data protection authority.
Email support@vmhunter.com from your account address. We reply within one month, extendable by two further months for complex requests. We do not carry out automated decision-making that produces legal or similarly significant effects about you.
If you were called by one of our customers and want to exercise your rights over that call, contact the company that called you: it is the controller. If you contact us, we will pass the request to the customer where we can identify it and assist them in responding.
4. Data processing terms (Art. 28)
When we process call data on your behalf, the following terms apply automatically. A countersigned Data Processing Agreement is available on request.
| Item | Terms |
|---|---|
| Subject matter and duration | Answering machine detection for calls you send us, for the term of your subscription. |
| Nature and purpose | Real-time analysis of a short audio sample, transcription, classification, storage of the sample, transcript and result for your review, support, security and service improvement on your instructions. |
| Data subjects | People you call. |
| Categories of data | Voice in the first seconds of the call, its transcript, the identifiers you choose to send (call or lead ID and, if your setup supplies them, the dialed number and the dialer's call ID), timestamps and results. You must not send special-category data deliberately. |
| Instructions | We process call data only on your documented instructions, which are these Terms, your configuration of the Service and your portal settings, unless the law requires otherwise, in which case we tell you first where permitted. |
| Confidentiality | People authorised to access call data are bound by confidentiality obligations. |
| Security | We apply the measures described in the Privacy Policy, section 8, and review them regularly. |
| Sub-processors | You authorise us to use sub-processors in the categories listed below. We impose data protection terms on them, remain responsible for their performance, and will give notice of new sub-processors so that you can object on reasonable grounds. |
| Assistance | We help you respond to data subject requests, carry out impact assessments and consult regulators, taking account of the nature of the processing. |
| Breach notification | We notify you without undue delay after becoming aware of a personal data breach affecting your call data, with the information you need to meet your own obligations. |
| Deletion and return | Audio samples are deleted 30 days after the call. You can delete recordings yourself at any time, switch recording storage off, and export call logs as CSV. On termination we delete remaining call data within 30 days unless the law requires us to keep it. |
| Audits | We make available the information reasonably needed to demonstrate compliance and will answer written security questionnaires once a year. On-site audits are by agreement, at your cost, and subject to confidentiality. |
5. Sub-processors
| Category | Purpose | Data |
|---|---|---|
| Speech recognition infrastructure provider | Converts the audio sample to text in real time. | Audio sample; no account data. |
| Hosting and data centre provider | Servers and storage for the Service, in the United States. | All Service data. |
| Email delivery provider | Account, usage and security notifications. | Your email address and message content; no call data. |
| Stripe | Payments and invoicing. | Billing details; no call data. |
The named list of current sub-processors for call data is provided to customers on request.
6. International transfers
Call data and account data are processed in the United States and, for some sub-processors, in other countries. For transfers of personal data from the EEA, the UK or Switzerland to countries without an adequacy decision, the European Commission's Standard Contractual Clauses (Module 2, controller to processor, for call data; Module 1 where we are a controller) and, where relevant, the UK International Data Transfer Addendum are incorporated into these terms by reference. We will sign them on request.
7. What you must do as controller
- Have a lawful basis for calling and for having the opening seconds of each call analysed and stored.
- Tell the people you call what they need to be told under Articles 13 and 14, including that a service provider analyses call audio.
- Decide whether recording storage should be on for your account, and turn it off if your legal basis does not cover retention.
- Send only the data detection requires, and avoid putting personal data into the call identifier field.
8. Contact
For data protection questions, a signed DPA or the sub-processor list, write to us. VM Hunter has not appointed a data protection officer or an EU/UK representative; if that changes we will publish the details here.
PILOTLAB LLC dba VM HUNTER
1309 Coffeen Ave Ste 1200, Sheridan, WY 82801, United States
Email: support@vmhunter.com
Website: vmhunter.com