1. Who We Are
CallPilot is operated by Swiftwave FZ-LLC, a company registered in Ras Al Khaimah, UAE (licence no. 47028798), registered office: Compass Building, Al Shohada Road, Al Hamra Industrial Zone-FZ, Ras Al Khaimah, UAE ("Swiftwave", "we", "us").
2. Our Role
For data our clients process through CallPilot (including applicant and candidate data), the client is the data controller and Swiftwave is the data processor, acting only on the client's documented instructions under our Data Processing Agreement (DPA). For our own account, billing and website data, Swiftwave is the data controller.
3. Information We Process
- Account data: name, email, phone number, company name and login credentials
- Technical data: IP address, device and browser details, logs and audit records
- ATS/CRM data: applicant records accessed through the client's ATS, CRM or HCM integration
- Call data: phone numbers, call time, duration and direction, and answers given during AI calls
- Transcripts: only where the client enables them (off by default)
- Documents: ID, qualifications and other files applicants send by WhatsApp, SMS upload link or email form
- AI outputs: call outcomes and status updates (for example Pre-qualified, Unsuccessful, AI Call - No Reply)
4. How We Handle It
ATS/CRM data
Accessed only to carry out the actions the client has set up. It is not copied, enriched or resold, and is not kept once the action is complete.
Calls
Processed in real time. CallPilot does not record calls or store audio.
Transcripts
Off by default. Where a client enables them, the client sets the retention period and transcripts are deleted automatically when it ends. The recommended maximum is five days.
Documents
Applicants reply in the WhatsApp chat with photos or files, use a secure SMS upload link, or use the email upload form. Documents are passed directly to the applicant's record in the client's ATS. Documents are not kept on the CallPilot platform once transferred.
Call outcomes
Written back to the client's ATS. The client's Talent Team remains responsible for all hiring decisions and for reviewing outcomes.
5. AI Model Training
Client data, including applicant information, call responses, transcripts and uploaded documents, is not used to train or fine-tune AI models by Swiftwave or its sub-processors.
6. Security
- Encryption in transit (HTTPS/TLS) and at rest
- Role-based access controls and restricted administrative privileges
- Secure cloud infrastructure with firewalls and network controls
- Monitoring, logging and audit trails
- Breaches notified to affected clients without undue delay, and to regulators where required by law
7. Sub-Processors
We use sub-processors for cloud hosting, AI processing, telephony, SMS and WhatsApp messaging (Meta WhatsApp Business Platform). All are contractually bound to data protection obligations. A current list is available on request from contact@swiftwave.ai.
8. International Transfers
Data may be processed outside the UAE. Where data originates in the UK or EU, transfers are protected by appropriate safeguards: the UK International Data Transfer Agreement or UK Addendum, and the EU Standard Contractual Clauses.
9. Retention
- Account data: for the length of the contract and a reasonable period afterwards, as required by law
- Transcripts: as set by the client, recommended maximum five days
- On termination: client data is deleted or returned in line with the contract
10. Legal Framework
This policy is governed by the UAE Personal Data Protection Law (Federal Decree Law No. 45 of 2021) and is designed to meet the requirements of the EU GDPR and UK GDPR for clients in those regions.
11. Your Rights
Subject to applicable law, you may request access to, correction, deletion or restriction of your personal data, object to processing, or withdraw consent. Where we process data for a client, we will pass your request to that client and assist them in responding.
Contact: contact@swiftwave.ai