Privacy Policy

1. Who This Policy Covers

This policy applies to two groups:

• Customers: the home services businesses that subscribe to Workings.
• Callers: the individuals, meaning Customer's customers or prospects, whose calls are answered, transcribed, and processed by the Service on Customer's behalf.

Workings acts as a service provider/processor of Caller personal information on behalf of our Customers, who act as the primary collector and controller of that information for their own business purposes.

2. Information We Collect

From Customers, meaning business users:

• Business name, contact details, service area, pricing rules, and account/login information.
• Billing information, processed via our payment provider.
• Configuration data used to run the Service, including escalation contacts, business hours, and service categories.

From Callers, via phone intake:

• Name, phone number, and address or service location.
• Description of the issue/job, urgency indicators, and access notes.
• Call audio recordings and/or transcripts generated by our AI system.
• Metadata such as call time, duration, and outcome, including booked, escalated, or no-go.

We do not intentionally collect sensitive categories of information, such as health information, financial account numbers, or government ID, unless a caller volunteers it during a call, in which case it is handled under the same safeguards described below.

3. How We Use Information

We use collected information to:

• Operate the Service, including answering calls, triaging urgency, and generating leads and summaries for Customer's team.
• Improve the accuracy and reliability of our AI models and call-handling logic.
• Provide Customers with reporting and analytics on call outcomes, such as lost-call reasons.
• Maintain security, prevent abuse, and comply with legal obligations.
• Communicate with Customers about their account and the Service.

We do not sell personal information, and we do not use Caller information to advertise to Callers.

4. AI Processing and Third-Party Providers

The Service uses third-party AI and telephony infrastructure providers to answer calls, transcribe audio, generate responses, deliver messages, and support related service functions. These providers process data on our behalf under contractual confidentiality and data protection obligations. Current providers may include Vapi for AI voice calling infrastructure, Twilio for telephony and messaging infrastructure, and OpenAI for AI model processing where configured.

5. Call Recording Disclosure

Calls handled by the Service may be recorded and processed by an automated system. Where required by law, an audible disclosure is provided to Callers at the start of the call. Customers are responsible for ensuring recording practices comply with the consent laws of the jurisdiction(s) in which they operate.

6. Data Retention

• Call recordings and transcripts are retained for 3 months to allow Customer review, dispute resolution, and service improvement, after which they are deleted or de-identified, unless a longer period is required by law or requested by the Customer.
• Account and billing data is retained for the duration of the subscription and for a period afterward as required for tax, accounting, or legal purposes.

7. How We Disclose Information

We may disclose personal information:

• To the Customer whose account generated the call, which is core to how the Service functions.
• To service providers who process data on our behalf, including hosting, AI processing, telephony, and analytics providers.
• Where required by law, subpoena, or valid legal process.
• In connection with a merger, acquisition, or sale of assets, subject to equivalent privacy protections.

8. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction, including encryption in transit and access controls. No system is completely secure, and we cannot guarantee absolute security.

9. Your Rights

Under PIPEDA and applicable provincial law, individuals have the right to:

• Request access to personal information we hold about them.
• Request correction of inaccurate information.
• Withdraw consent, where consent is the basis for processing, subject to legal or contractual restrictions.
• File a complaint with the Office of the Privacy Commissioner of Canada or the relevant provincial regulator.

Callers who wish to exercise these rights should generally contact the Customer they called, as the Customer is typically the primary holder of that relationship. Workings will assist Customers in fulfilling such requests. Callers may also contact us directly at michellebrookskelly@gmail.com.

10. Children's Privacy

The Service is not directed at children, and we do not knowingly collect personal information from children.

11. International Data Transfers

Personal information may be processed or stored on servers located outside of Canada, including in the United States, depending on our service providers' infrastructure. By using the Service, you acknowledge that such information may be subject to the laws of those jurisdictions.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated "Last updated" date.

13. Contact Us

Questions, access requests, or complaints regarding this Privacy Policy can be directed to:

Workings

michellebrookskelly@gmail.com