Privacy Policy

1. Introduction

Olelo Intelligence, Inc. ("Olelo," "Company," "we," "us," or "our") provides AI-powered conversation intelligence and revenue recovery tools for service-based businesses. This Privacy Policy describes how we collect, use, store, and protect information when businesses ("Customers") use our platform and when their employees and end consumers ("End Users") interact with our services.

This policy applies to data processed through the Olelo platform, including our website at olelo.ai, our platform accessed at olelointelligence.com, our analytics dashboard, and our AI Voice Agent.

2. Information We Collect

2.1 Customer Account Information

When a business subscribes to Olelo, we collect:

• Business name, address, and contact information
• Billing and subscription details
• Account administrator names and email addresses
• VoIP provider credentials (OAuth tokens or API keys) for call recording access
• Google Business Profile (OAuth tokens or API keys) for location performance access
• Call Tracking provider credentials (OAuth tokens or API keys) for call recording access
• Business Operation, including but not limited to appointment programs, CRM's or POS provider credentials (OAuth tokens or API keys) for business automation and performance insight metrics such as average sale.

2.2 Call Data

Through integration with Customer VoIP providers, we access and process:

• Call recordings (audio files): Downloaded from the Customer's existing VoIP provider. Customers record calls as part of their existing business operations — Olelo does not initiate or control call recording.
• Call transcriptions: Generated by our speech-to-text processing pipeline and made available in the platform.
• Call metadata: Timestamps, duration, call direction (inbound/outbound), and phone numbers.

2.3 Analysis Data

Our platform generates:

• Behavioral tag assessments
• Multi-dimensional performance scores
• Coaching recommendations mapped to specific coaching lessons
• Revenue impact predictions and recovery opportunity identification
• Aggregated location-level and brand-level performance metrics

2.4 AI Voice Agent Data

For Customers using our AI Voice Agent (after-hours and overflow call handling):

• Inbound call audio and transcriptions
• Appointment booking details
• Caller information provided during the conversation

2.5 SMS Communication Data

When our AI Voice Agent sends a text message at a caller's request during an active inbound call:

• The recipient's phone number, captured automatically from the inbound caller ID of the active call
• The content of the message sent (e.g., a link to directions, financing options, or service information)
• No SMS-related data is stored for future marketing use. Phone numbers captured for SMS delivery are used solely to deliver the requested message.

Sales Follow-Up SMS Data

When an Olelo Intelligence sales representative sends a follow-up text message to a prospective business customer after an outbound phone call:

• The recipient's phone number, provided during the outbound sales call
• The content of the message sent (e.g., demo scheduling links, case studies, product information)

Sales follow-up SMS is sent only after the recipient provides verbal consent during the phone call to receive a text message. Phone numbers used for sales follow-up SMS are used solely for the stated follow-up purpose and are not shared with third parties for their marketing purposes.

Appointment Confirmation and Reminder SMS Data

When Olelo sends appointment confirmation or reminder text messages to a consumer who has booked a service appointment with one of our business customers (auto repair shops):

• The recipient’s mobile phone number, provided during the booking call
• The content of the message sent (appointment confirmations, reminders, reschedule and cancel links, and confirmation acknowledgments)

Appointment confirmation and reminder SMS is sent only after the consumer provides verbal consent during the booking call to receive a text message about the appointment. Phone numbers used for appointment messaging are used solely for that purpose and are not shared with third parties for their marketing purposes.

2.6 Website and Dashboard Usage

• Browser type, IP address, and device information
• Pages visited and features used within the analytics dashboard
• Cookies and similar tracking technologies (see Section )

3. How We Use Information

We use the information we collect to:

• Provide the Service: Analyze calls, generate coaching recommendations, identify revenue recovery opportunities, and deliver performance dashboards.
• Improve the Platform: Refine our behavioral taxonomy, improve AI model accuracy, and develop new product features.
• Customer Support: Respond to inquiries, troubleshoot issues, and assist with onboarding.
• Billing and Administration: Process payments, manage subscriptions, and maintain account records.
• Aggregate Analytics: Generate anonymized, aggregated benchmarks and insights across our customer base (no individual call data is shared between Customers).
• SMS Delivery: Send transactional text messages to consumers and prospects who have provided verbal consent, including caller-requested information during active inbound call sessions, appointment confirmations and reminders for booked appointments, and sales follow-up messages to prospective business customers.

We do not:

• Sell personal information to third parties
• Use call recordings or transcriptions for advertising purposes
• Share individual Customer data with other Customers
• Use Customer data to train AI models in a way that exposes one Customer's data to another
• Ask for or intentionally store payment card numbers, CVV codes, or social security numbers from call recordings
• Send SMS marketing messages or store consumer phone numbers for future marketing use

4. How We Store and Protect Information

4.1 Infrastructure

All data is stored in Amazon Web Services (AWS) data centers. Infrastructure uses encryption in transit (TLS) and at rest across all storage services.

4.2 Security Measures

• Encryption in transit: All data transmitted via TLS/HTTPS
• Encryption at rest: All storage services use encryption at rest (SSE-S3, AES-256, DynamoDB encryption)
• Network isolation: Database services deployed in VPC private subnets with security group restrictions
• Access control: AWS IAM with least-privilege policies; secrets managed through AWS Secrets Manager
• Environment isolation: Separate AWS accounts for development, staging, and production environments with no cross-environment data access
• Monitoring: CloudWatch logging for all service executions, API requests, and error tracking

4.3 Employee Access

Access to Customer data is limited to authorized Olelo personnel who require such access to perform their job functions (e.g., engineering, customer support). Access is granted on a need-to-know basis and is governed by AWS IAM least-privilege policies, with activity audited through CloudWatch logs. All Olelo personnel with access to Customer data are subject to written confidentiality obligations that survive the termination of their employment or engagement with Olelo. Personnel with data access receive appropriate training on their data protection responsibilities prior to being granted access.

4.4 Data Processing Addendum

Business customers who subscribe to the Olelo platform are subject to a Data Processing Addendum ("DPA") that governs Olelo's obligations as a data processor with respect to personal data processed on behalf of Customer. The DPA forms part of the Agreement and is available upon request by contacting privacy@olelo-ai.com. In the event of any conflict between this Privacy Policy and the DPA with respect to the processing of personal data on behalf of a business customer, the DPA shall govern.

5. Data Retention

Our data retention practices are described in detail in our Data Retention Policy. In summary:

Call recordings (MP3): 24 months from date of processing

• AI Voice Agent recordings: 24 months from date of processing
• Call transcriptions (JSON): 24 months from date of processing
• Analysis results (structured): Duration of customer contract + 12 months
• Call metadata: Duration of customer contract + 12 months
• Account information: Duration of customer contract + 24 months
• Appointment confirmation SMS records: 24 months from date of delivery
• SMS delivery records (other transactional): 30 days from date of delivery
• Aggregated/anonymized analytics: Indefinite (no PII)
• Sales follow-up SMS records: 90 days from date of delivery

After the retention period expires, data is automatically deleted through S3 lifecycle policies and scheduled database cleanup processes.

Business customers may request export of their Customer Data in a commonly used electronic format at any time prior to the expiration of the applicable retention period by submitting a written request to privacy@olelo-ai.com. Olelo will fulfill such requests within 10 business days of receipt.

6. Data Sharing and Subprocessors

We share Customer data only with the following categories of service providers, each of which processes data solely on our behalf and subject to contractual data protection obligations:

Our Subprocessors:

• Amazon Web Services (AWS): Cloud infrastructure — accesses all data
• Amazon Bedrock: AI model inference for call analysis — accesses call transcriptions (text only, no audio)
• Deepgram: Speech-to-text transcription — accesses call recordings (audio)
• ElevenLabs: AI Voice Agent voice synthesis — accesses voice agent call audio
• SMS Delivery Provider: Transactional, appointment confirmation, and sales follow-up SMS delivery — accesses recipient phone number and message content only
• Customer's VoIP Provider: Source of call recordings — accesses call recordings via provider API

We do not share Customer data with any other third parties except:

• When required by law, regulation, or legal process
• To protect the rights, property, or safety of Olelo, our Customers, or the public
• In connection with a merger, acquisition, or sale of assets (with notice to affected Customers)

7. Call Recording Consent

Olelo does not initiate or control call recording. Customers record phone calls through their own VoIP providers as part of their existing business operations.

Customer Responsibility: Each Customer is responsible for ensuring that call recordings comply with all applicable federal and state laws, including consent requirements in two-party consent states (e.g., California, Florida, Illinois, Pennsylvania, Washington). Customer agreements with Olelo include representations that Customers have obtained all necessary consents for call recording.

Olelo's Role: Olelo acts as a data processor with respect to call recordings. We access recordings that Customers have already made and process them to provide our analytics and coaching services.

8. SMS Communications

Olelo Intelligence may send SMS text messages in three distinct contexts described below. In every context, SMS is sent only after the recipient provides verbal consent during a phone call. No marketing messages are sent on any of these flows.

In-Call AI Voice Agent SMS

Olelo Intelligence may send SMS text messages to individuals who explicitly request them during an active inbound phone call to one of our business customers. These messages are transactional in nature and contain only the specific information the caller requested — such as a link to directions, financing options, or service information.

How we obtain consent: During an active inbound call, our AI voice agent offers to send a relevant link via text message. An SMS is only sent after the caller verbally confirms they would like to receive it. No SMS messages are sent outside of an active call session, and no marketing messages are sent via SMS.

Phone number collection: The recipient’s phone number is captured automatically from the inbound caller ID of the active call. This number is used solely to deliver the requested message and is not stored for future marketing purposes.

Message frequency: Typically 1 message per call session. Message frequency may vary.

Msg & Data Rates May Apply.

To opt out: Reply STOP to any message to unsubscribe. You will receive a confirmation and no further messages will be sent.

For help: Reply HELP to any message for assistance, or contact us at privacy@olelo-ai.com.

Olelo Intelligence does not share your phone number with third parties for their marketing purposes.

Appointment Confirmation and Reminder SMS

Olelo Intelligence sends transactional SMS text messages to customers of our participating auto repair shops and service-based business clients to confirm and remind them of scheduled service appointments. These messages are tied to a specific scheduled appointment and are not used for marketing, promotion, or sales.

How we obtain consent: Consent is captured verbally during a phone call to a participating shop, before any SMS is sent. When a human service advisor takes the booking call, the advisor asks the customer for permission to send appointment-related text messages (for example: "We can send you a text message to confirm your appointment and let you reschedule if you need to. Is it okay if we text you at this number?"). When our AI Voice Agent takes the booking call (after-hours or overflow), the AI Voice Agent asks the customer the equivalent question. A phone number is enrolled in the appointment confirmation and reminder program only after the customer affirmatively agrees on the call. The complete consent process, including the exact verbal scripts used by service advisors and the AI Voice Agent, sample messages, message frequency, and opt-out instructions, is publicly documented at https://olelo.ai/sms-terms.

Phone number collection: The recipient's phone number is provided by the customer during the booking call and is associated with the customer's appointment record in the shop's scheduling system. Phone numbers collected for appointment confirmation SMS are used solely to deliver the messages described in this section.

Consent documentation and Send Gate: Every booking call to a participating shop is recorded and transcribed as part of the shop's existing business operations. The audio and transcript of the consent exchange are timestamped and retained for twenty-four (24) months. Olelo's platform applies a technical control referred to as the "Send Gate" that blocks any SMS from being sent unless a documented consent record is on file for the recipient's phone number.

Message content: Appointment confirmation, appointment reminder, reschedule prompt, and confirmation acknowledgment messages. Each message identifies the participating shop by name and includes a "powered by Olelo" reference, the shop's contact phone number, and opt-out and help instructions.

Message frequency: Typically 2–4 messages per appointment, varying by how far in advance the appointment is scheduled and whether the customer confirms.

Msg & Data Rates May Apply.

To opt out: Reply STOP to any message to unsubscribe. You will receive a one-time confirmation, and no further appointment messages will be sent to you from that shop. Olelo also honors STOPALL, UNSUBSCRIBE, CANCEL, END, and QUIT as equivalent opt-out keywords. Reply START to re-subscribe.

For help: Reply HELP to any message for assistance, or contact us at privacy@olelo-ai.com.

Olelo Intelligence does not share your phone number with third parties for their marketing purposes.

Sales Follow-Up SMS

Olelo Intelligence sales representatives may send SMS text messages to prospective business customers who have provided verbal consent during an outbound phone call. These messages are one-to-one and conversational — sent by a named Olelo representative to a specific business prospect.

How we obtain consent: During an outbound phone call with a prospective business customer, the Olelo representative asks for verbal permission to send a follow-up text (e.g., “Can I text you that demo link after we hang up?”). An SMS is only sent after the prospect explicitly agrees.

Message content: Demo scheduling confirmations, follow-up on topics discussed during the call, links to case studies or product information.

Message frequency: Typically 1-3 messages per contact, varying by engagement.

Msg & Data Rates May Apply.

To opt out: Reply STOP to any message to unsubscribe. You will receive a confirmation and no further messages will be sent.

For help: Reply HELP to any message for assistance, or contact us at privacy@olelo-ai.com.

9. Cookies and Tracking

Our website and analytics dashboard use cookies and similar technologies for:

• Essential cookies: Required for authentication, session management, and security
• Functional cookies: Remember user preferences and dashboard settings
• Analytics cookies: Understand how users interact with our dashboard to improve the product

Remarketing and Personalized Advertising

We use remarketing and retargeting technologies to advertise Olelo Intelligence across the internet. After you visit our websites at olelo.ai or olelointelligence.com, you may see ads for Olelo Intelligence on other websites, apps, and platforms. We use advertising cookies and pixels placed by the following third-party vendors for this purpose:

• Google Ads (Google LLC): Uses cookies and device identifiers to serve ads based on your past visits to our websites, across Google Search, YouTube, and the Google Display Network.
• Meta Pixel (Meta Platforms, Inc.): Used to deliver retargeted ads on Facebook and Instagram based on your interactions with our websites.
• LinkedIn Insight Tag (LinkedIn Corporation): Used to track conversions, retarget website visitors, and gain insights about our LinkedIn ad campaigns.
• TikTok Pixel (TikTok Inc.): Used to measure ad performance and serve retargeted ads on TikTok to users who have previously visited our websites.
• X Ads (X Corp., formerly Twitter): Used to deliver tailored ads on X.com to users who have interacted with our websites.

These third-party vendors use cookies, pixels, and device identifiers to recognize your browser or device across different websites and platforms. Their use of these technologies is governed by their own privacy policies, not ours.

We may share certain first-party customer information — such as hashed email addresses or phone numbers provided directly to us — with Google LLC to measure the effectiveness of our advertising campaigns through Google's Enhanced Conversions feature. This data is used solely for ad measurement purposes on our behalf and is subject to Google's Ads Data Processing Terms. Where required by applicable law, we obtain customer consent before sharing such data.

You can opt out of personalized advertising from these vendors using the following links:

• Google: https://adssettings.google.com
• Meta (Facebook & Instagram): https://www.facebook.com/adpreferences/
• LinkedIn: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
• TikTok: https://www.tiktok.com/legal/page/us/privacy-policy/en
• X (Twitter): https://twitter.com/settings/personalization
• All vendors (Network Advertising Initiative): https://optout.networkadvertising.org

10. Your Rights

10.1 For Customer Businesses

Customers may:

• Access their data through the Olelo analytics dashboard
• Request deletion of all data (recordings, transcriptions, analysis results) by submitting a written request to privacy@olelo-ai.com. Deletion will be completed within 30 days and confirmed in writing.
• Terminate their subscription, triggering data retention and deletion per Section 5
• Request export of their Customer Data in a commonly used electronic format by submitting a written request to privacy@olelo-ai.com. Export requests will be fulfilled within 10 business days.

10.2 For End Consumers (Callers)

If you are an individual whose call was recorded and analyzed through the Olelo platform:

• Recording consent inquiries should be directed to the business you called, as they control the recording process
• Data access or deletion requests can be submitted to privacy@olelo-ai.com. We will work with the relevant Customer to fulfill your request within 30 days.
• To opt out of SMS messages, reply STOP to any message you receive

10.3 California Residents (CCPA/CPRA)

Olelo does not currently meet the CCPA/CPRA applicability thresholds based on annual revenue, data volume, and data sales criteria. We will reassess CCPA applicability as the business scales and will update this policy accordingly. Regardless of CCPA applicability, California residents may exercise the access and deletion rights described above.
Residents of other U.S. states with applicable privacy laws — including but not limited to Texas, Virginia, Colorado, Connecticut, Florida, Oregon, Montana, Tennessee, Indiana, and Iowa — may also exercise rights of access, correction, deletion, and data portability with respect to their personal information by submitting a request to privacy@olelo-ai.com. Olelo will respond to all such requests within 45 days, which may be extended by an additional 45 days where reasonably necessary, consistent with applicable law.

11. Children's Privacy

Olelo's services are designed for business use. We do not knowingly collect personal information from individuals under 16 years of age. If we learn that we have collected personal information from a child under 16, we will delete that information promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to Customers via email and posted on our website with an updated "Last Updated" date. Continued use of the platform after changes constitutes acceptance of the updated policy.

13. Contact Us

For questions about this Privacy Policy or to exercise your data rights:

• Email: privacy@olelo-ai.com
• Mail: Olelo Intelligence, Inc., Delaware

For general support: support@olelo-ai.com

Olelo Intelligence, Inc. is a Delaware corporation.