1. Scope & Application
This Privacy Policy applies to personal data processed through:
- Swiftwave FZ-LLC
- The Swiftwave website
- The Swiftwave platform
- All AI modules, services, and applications operated by Swiftwave
- CallPilot.pro (a Swiftwave product)
- The CallPilot website
- The CallPilot platform
- AI-powered calling functionality, including CallPilot AI Phone Call
- Related communication, automation, and analytics services
This policy covers personal data collected via:
- Websites and web applications
- Platforms, dashboards, and APIs
- Customer relationship management (CRM) systems, including data synced, imported, or integrated from third-party CRMs authorised by customers
- Integrations with third-party systems, tools, and services connected by customers
- AI-driven interactions, including CallPilot.pro AI Phone Call, call transcripts, call text, and AI-generated outputs
2. Who We Are
- Company: Swiftwave FZ-LLC
- Jurisdiction: United Arab Emirates
- Products: CallPilot.pro and other Swiftwave AI modules
Swiftwave acts as a Data Controller and/or Data Processor, depending on the nature of the service and the contractual relationship with customers.
3. Personal Data We Collect
a) Identity & Contact Data
- Name
- Email address
- Phone number
- Company name
- User account credentials
b) Technical & Usage Data
- IP address
- Device and browser information
- Log files and audit records
- Platform usage and interaction data
c) CRM & Customer-Provided Data
- Personal data stored in customer CRM systems
- Data imported, synced, or transmitted via APIs or integrations
Swiftwave processes CRM data only transiently and does not store or retain CRM personal data.
d) CallPilot.pro AI Phone Call Data
- Phone numbers
- Call metadata (time, duration, direction)
Call recordings, call transcripts, and call text are not stored by Swiftwave.
4. How We Use Personal Data
Personal data is used to:
- Operate and deliver Swiftwave and CallPilot.pro services
- Enable AI-powered functionality, including CallPilot.pro AI Phone Call
- Execute customer-initiated actions using CRM-sourced data
- Maintain platform security, reliability, and performance
- Provide customer support and account management
- Improve and develop products and features
- Comply with legal and regulatory obligations
- Detect, prevent, and investigate misuse or unlawful activity
5. AI Processing & Automated Systems
Swiftwave products use artificial intelligence and automated systems to:
- Conduct or assist communications
- Analyse speech and text
- Generate summaries, insights, classifications, or recommendations
Human oversight mechanisms are in place. Swiftwave does not make legal, employment, or compliance decisions on behalf of customers.
6. Lawful Basis & Global Data Protection Alignment
Personal data is processed in accordance with the UAE Personal Data Protection Law (PDPL) and is designed to align with internationally recognised data protection and privacy frameworks, including:
- EU General Data Protection Regulation (GDPR)
- UK GDPR
- Other comparable national and regional data protection and privacy laws worldwide
Swiftwave applies core privacy principles common to these frameworks, including:
- Lawfulness, fairness, and transparency
- Purpose limitation
- Data minimisation
- Storage limitation
- Security and confidentiality
- Accountability
Due to the architecture of Swiftwave products — including automatic deletion of call recordings, non-retention of CRM personal data, and no storage of call text — Swiftwave's services are designed to support compliance across multiple jurisdictions.
Where Swiftwave acts as a data processor, customers remain responsible for:
- Determining lawful processing purposes
- Providing required notices
- Obtaining any necessary consents
- Ensuring compliance with local laws applicable to their use case
7. Call Consent & Customer Responsibility
Customers using CallPilot.pro AI Phone Call functionality are solely responsible for:
- Providing lawful call notices
- Obtaining any required consent from call participants
- Ensuring CRM data is lawfully collected and shared
- Complying with applicable telecoms, privacy, and data protection laws
Swiftwave provides the technology platform and does not control the legality or purpose of individual customer communications.
8. Call Recording & Call Text Handling
- Swiftwave does not retain call recordings at any time.
- Swiftwave does not store call transcripts or call text.
Any temporary availability of call text or transcripts for quality review is customer-controlled, occurs outside of Swiftwave's data storage, and is limited to a recommended maximum review period of five (5) days.
9. Data Sharing, CRM Data Handling & Sub-Processors
Swiftwave processes personal data only as necessary to provide its services and strictly in accordance with customer instructions.
CRM Data Handling (Important Clarification)
- Swiftwave does not store, maintain, or retain personal data originating from customer CRM systems.
- CRM personal data is accessed transiently and securely for the sole purpose of executing customer-initiated actions.
- Once the relevant action is completed, CRM personal data is not persisted within Swiftwave systems.
- Swiftwave does not copy, replicate, enrich, resell, or independently use CRM personal data.
Sub-Processors
Personal data may be processed by vetted third-party sub-processors solely to support service delivery, including:
- Cloud infrastructure providers
- Security, monitoring, and logging services
- AI and telecommunications service providers
All sub-processors are contractually required to:
- Process data only on Swiftwave's instructions
- Apply appropriate security measures
- Comply with applicable data protection laws
Swiftwave does not sell personal data.
10. International Data Transfers
Personal data may be processed outside the UAE where necessary to provide services. Appropriate safeguards are applied in accordance with UAE PDPL and GDPR-aligned standards.
11. Data Retention
Personal data is retained only for as long as necessary to:
- Provide services
- Meet contractual, legal, or regulatory obligations
CRM personal data is not retained by Swiftwave. Call recordings are not retained. Call text and transcripts are not stored by Swiftwave.
12. Data Security
Swiftwave implements appropriate technical and organisational measures, including:
- Encryption in transit and at rest
- Role-based access controls
- Secure cloud infrastructure
- Monitoring, logging, and audit trails
13. Individual Rights
Subject to applicable law, individuals may request:
- Access to personal data
- Correction of inaccurate data
- Deletion or restriction of processing
- Withdrawal of consent where applicable
14. Children's Data
Swiftwave products are not intended for use by children. We do not knowingly collect personal data from minors.
15. Changes to This Policy
This Privacy Policy may be updated from time to time. Continued use of Swiftwave or CallPilot.pro services constitutes acceptance of the updated policy.
16. Contact Information
For privacy or data protection enquiries, you may contact:
Swiftwave FZ-LLC
Registered office: United Arab Emirates
Registered address: As recorded with the relevant UAE Free Zone Authority
Registration number: 47028798
Email: contact@swiftwave.ai
