Privacy Policy
Last updated: May 2026
§ 1 Controller
The controller responsible for data processing on this website is:
Avya Labs
Floridaring 56, 70806 Kornwestheim, Germany
Email: hi@avya-labs.com
§ 2 Data Collected via Contact Form
When you submit the contact form, we process the following data you provide: name, email address, website URL, and project description. This data is used solely for the purpose of responding to your enquiry and initiating a potential project collaboration.
§ 3 Legal Basis
Processing of contact form data is carried out on the basis of your explicit consent pursuant to Art. 6(1)(a) GDPR. You may withdraw consent at any time by contacting us at hi@avya-labs.com.
§ 4 Retention Period
Your data will be deleted once it is no longer required for the purpose for which it was collected, and no later than 24 months after your last contact with us.
§ 5 Your Rights
Under the GDPR you have the following rights regarding your personal data:
- Right of access (Art. 15 GDPR)
- Right to rectification (Art. 16 GDPR)
- Right to erasure (Art. 17 GDPR)
- Right to restriction of processing (Art. 18 GDPR)
- Right to data portability (Art. 20 GDPR)
- Right to object (Art. 21 GDPR)
To exercise any of these rights, please contact us at: hi@avya-labs.com
§ 6 Right to Lodge a Complaint
You have the right to lodge a complaint with a data protection supervisory authority. The competent authority is the data protection commissioner of the German federal state in which our company is based (Baden-Württemberg): www.baden-wuerttemberg.datenschutz.de.
§ 7 Website Hosting
Vercel, Inc.
340 Pine Street, Suite 900, San Francisco, CA 94104, USA
This website is hosted by Vercel. When you visit the site, Vercel's servers automatically collect and store technical access data (IP address, browser type, operating system, date and time of access, pages visited). This processing is necessary for the technical delivery of the website.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the secure and reliable operation of the website).
Data transfer to third country: The USA. Vercel has entered into the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR) to ensure an adequate level of data protection.
Vercel privacy policy: vercel.com/legal/privacy-policy
§ 8 Web Analytics (Vercel Web Analytics)
Vercel, Inc.
340 Pine Street, Suite 900, San Francisco, CA 94104, USA
We use Vercel Web Analytics to count visitors and pageviews on our marketing pages (homepage and voice-agent landing page) for usability analysis and capacity planning. The legal information pages (this Privacy Policy and the Imprint) are excluded from analytics.
Data processed: URL path, HTTP referrer, anonymised user-agent (browser family, operating system family), and country of origin derived from the IP address at request time. IP addresses are processed in accordance with Vercel's privacy policy (linked below). No cookies, no localStorage, no sessionStorage, and no browser fingerprinting are used.
Legal basis: Art. 6(1)(f) GDPR — our legitimate interest in understanding aggregate traffic for usability and capacity planning. TTDSG § 25 does not apply to this processing because no information is stored on or accessed from your terminal device.
Data transfer to third country: The USA. Vercel has entered into the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR), as stated in § 7 above.
Right to object: You may object to this processing at any time by contacting us at hi@avya-labs.com (Art. 21 GDPR).
Vercel privacy policy: vercel.com/legal/privacy-policy · Vercel Web Analytics: vercel.com/docs/analytics
§ 9 Fonts
This website uses the typefaces Outfit, Inter, and Cormorant Garamond. These fonts are self-hosted — the font files are served directly from our own server. No data is transferred to Google or any other third party for font delivery.
§ 10 Appointment Booking (Cal.com)
Cal.com, Inc.
USA
We use Cal.com for scheduling consultation appointments. The booking calendar is not loaded automatically. Where the calendar would appear, our website displays a placeholder card with a "Show booking calendar" button. No data is sent to Cal.com until you click that button. Only when you click does the Cal.com embed load and your IP address and browser information get transmitted to Cal.com's servers. If you proceed to book an appointment, Cal.com will also process your name, email address, and your chosen appointment time.
After a booking is confirmed, our server retrieves the booking record from Cal.com's API in order to render a personalised confirmation screen on our website. The retrieved data is limited to your name and your answer to the optional booking question regarding the AI lead qualification call. This is server-to-server access to data Cal.com already processes on our behalf and does not involve any additional third party.
Legal basis: Art. 6(1)(a) GDPR (your explicit consent, given by clicking "Show booking calendar") and § 25(1) TTDSG (consent for embedded service storage access). You may withhold this consent simply by not clicking the button; the rest of the website remains fully accessible.
Data transfer to third country: The USA. Cal.com operates under the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).
Cal.com privacy policy: cal.com/privacy
§ 11 Self-hosted Libraries
This website's CSS framework (Tailwind CSS) and 3D graphics library (Three.js) are self-hosted on our own servers. No data is transmitted to any third-party CDN provider when loading these resources.
§ 12 Cookies and Local Storage
This website does not set any cookies and does not use any non-essential client-side storage. The cookieless visitor counting described in § 8 writes nothing to your device. Embedded third-party services such as the Cal.com booking calendar are loaded only after you explicitly click to load them (see § 10), so no third-party cookies or storage are written to your device unless and until you give that consent.
§ 13 Outbound AI Voice Calls — Lead Qualification
When a lead books a discovery call on our website, they are asked whether they consent to receive an outbound call from our AI voice assistant to assess whether Avya Labs' services are a good fit for their needs. This process is called lead qualification. The outbound call is initiated only if the lead explicitly opts in during booking or provides consent via the post-booking overlay.
A second consent path exists: after completing a booking without opting in, the lead may be shown a post-booking overlay and offered the opportunity to consent to a call by ticking a checkbox and clicking "Yes, call me now". No call is made unless the checkbox is checked and the button is clicked.
Data processed: Full name, phone number, call recording, conversation transcript, structured call analysis summary, lead qualification assessment.
Call recording: Every call made by the AI voice assistant is recorded for lead quality analysis, training of Avya Labs' AI lead qualification voice assistant, and quality assurance. In compliance with § 201 StGB (prohibition of recording private speech without consent), the call begins with an automated announcement that the conversation is being recorded and is used for lead qualification purposes. By remaining on the call after this announcement, the caller provides implicit consent to the recording under § 201(1) StGB. The explicit booking consent or overlay consent under Art. 6(1)(a) GDPR constitutes the legal basis for initiating the call and any related processing.
Automated analysis and human review: The call transcript and recording may be automatically analysed by AI systems to generate a lead qualification recommendation (e.g. a summary of the lead's needs and fit for Avya Labs' services). This recommendation is always reviewed by a member of the Avya Labs team before any decision regarding your inquiry is made or acted upon. No decision based solely on automated processing is applied without human review.
Legal basis: Art. 6(1)(a) GDPR — explicit consent given either during booking or via the post-booking consent overlay.
Retention: Call recordings and transcripts are stored on the infrastructure of our AI voice calling service provider. Retention periods are governed by the provider's data processing agreement (typically 30–90 days). You may contact us to request earlier deletion.
Rights: You may withdraw consent at any time by contacting us at hi@avya-labs.com. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal (Art. 7(3) GDPR).
Applicable regulations: § 201 StGB (call recording); Art. 6(1)(a), Art. 7, Art. 13 GDPR (consent and transparency); Art. 5(1)(e) GDPR (storage limitation).
AI Voice Calling Service Provider (currently: VAPI Inc.)
USA
We use a third-party AI voice calling platform to initiate and conduct outbound lead qualification calls. This provider processes call audio, transcripts, metadata, and structured call analysis outputs on our behalf. Our current provider is VAPI Inc. (USA). If we change providers, this section will be updated accordingly, and where required by law, we will notify affected data subjects in advance.
Legal basis: Art. 6(1)(a) GDPR — consent given by the lead at the time of booking or via the post-booking overlay.
Data transfer to third country: The USA. Data transfers are covered by EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).
Current provider privacy policy: vapi.ai/privacy
Workflow Automation (n8n, self-hosted on Hostinger)
EU (Hostinger International Ltd., Kaunas, Lithuania)
We self-host the workflow automation software n8n on servers provided by Hostinger. When a lead consents to receive a qualification call, their name and Cal.com booking reference are sent to this system, which triggers the outbound call via our AI voice calling provider. Personal data processed: full name, Cal.com booking identifier. The n8n software developer (n8n GmbH, Berlin, Germany) does not have access to any personal data processed by our self-hosted instance.
Legal basis: Art. 6(1)(a) GDPR — consent given by the lead at the time of booking or via the post-booking overlay.
Data transfer: Data is processed on Hostinger's EU infrastructure. No international transfer applies. If the server region changes, this section will be updated.
Hostinger privacy policy: hostinger.com/privacy-policy
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