Data Controller
The controller of personal data collected through ClosePeak is:
SASU with a share capital of 100 €
Registered office and postal address: 149 avenue du Maine, 75014 Paris
Trade register Paris 981 590 656 · SIREN 981 590 656
Personal data contact: privacy@closepeak.io
Data Collected
When using the ClosePeak service and browser extension, the following data is collected:
- Call audio: the sales representative's voice captured via the device microphone, and the prospect's voice captured via the audio of the active call-platform tab (Google Meet, including from Gmail, or the Microsoft Teams, Zoom or Webex web client)
- Transcriptions: text automatically generated from audio streams
- Call metadata: duration, date, talk ratio, session identifier
- Account data: email address, name, user identifier
- Subscription data: subscribed plan, renewal date
- Team data, for the Agency plan: invitations sent, date of joining the team, monthly hour limit, acceptance of the team terms, dates and reason of a departure, calls shared with the admin account and comments on those calls, contributions to the team's shared challenges, company documents uploaded by the admin account (extracted text) and the team brief drawn from them
- Browsing data on public pages: the page viewed, the site you came from and a temporary visit identifier, excluding your IP address. This data is not attached to an account and is collected only on pages reachable without signing in
Processing Purposes
The collected data is processed for the following purposes:
Data Recipients
Your data may be shared with the following categories of service providers acting as data processors:
Agency teams
In the Agency plan, an admin account invites members by email. The invitation carries the invited person's address; it is valid for 7 days, and an invitation that has not been accepted is deleted 30 days after it expires.
What the admin account sees, for each account in the team, its own included: their name, email address, date of joining the team, the copilot hours used in the current cycle and their monthly limit. For the calls made since joining the team, and for those only, it also sees their report: date, duration, platform, the prospect's name entered by the member, scores, summary, key moment, objections found with their advice, recommended actions, and the verdicts on the team criteria. Finally, it sees a team overview, which groups the members' scores and objections, the admin account excluded, once at least three members have an analyzed call over the period. This overview names no member, but the admin account already reads every report.
What it does not see, unless a call is shared: the call transcripts, nor the prospect's exact words recorded in the objections. Reports are written without quoting the prospect's words; on a report produced before this change, the texts (summary, key moment, advice and actions) are not shown to it, only the scores and objections are.
Sharing a call. A member can share a call made since joining the team with the admin account, on their own initiative or at its request, which they can also decline. The admin account can then read that call's transcript, the prospect's words included, and comment on each line; the member gives each comment a status. No other member sees a shared call or its comments. The share and its comments are deleted when the member removes it, when they leave the team, when the call is deleted, and at the latest together with the transcript, after 6 months. While the team's subscription is unpaid, the member can only remove a share or decline a share request; no other share or comment can be changed.
Monthly ranking. If the admin account turns it on, every account in the team, admin account included, sees for all the others their name, the XP earned in the month since they joined the team and their rank, and nothing else: no email address, no score, no report. It is off by default. Nothing is kept for it: it is computed each time it is shown, from the XP already recorded. A member who leaves the team no longer appears in it.
Team criteria. The admin account can write 1 to 5 criteria. Every analyzed call from a team account, made since joining, gets one verdict per criterion (yes, partly, no or not applicable), produced by the same analysis as the report: the text of the criteria is therefore sent to the analysis provider together with the transcript, with no additional transfer. Each verdict is kept with the call's analysis, with a copy of the criterion; it is deleted with the call or the account, and stays in the member's history if they leave the team. The admin account sees the verdicts in the report of each call; a member sees those of their own calls, never those of another. A person's verdicts, and for the admin account the criteria it wrote, are included in the export of their data.
Exports. With the Pro and Agency plans, a call report can be saved as PDF using the browser's print function: the file is produced on your device, nothing is sent to us and we keep no copy. It contains what the screen shows, and never the transcript, even when shared: a member finds in it the prospect's words quoted by their own report; on a member's report, the admin account sees none. The admin account can also download a CSV file of the team's results: one row per call analyzed since each account joined, its own included, with the account's name (or, failing that, its email address), the date, the prospect's name entered by the member, the platform, the duration, the scores, the talk time, the number of objections, the outcome and the criteria verdicts. This file contains no written text, no transcript and nothing the prospect said. It is produced on request and we keep no copy; once downloaded, it is the admin account's responsibility.
Team offer analysis. The admin account of an active team can run, at most once a week and once its sellers have five analyzed calls, a diagnosis of the offer the team sells. It is produced by the analysis provider from the reports of the calls members made since joining, without the admin account's calls: scores, objections (type, severity, handling and moment), criteria verdicts, summary and key moment of the reports written without quotes only, and the description of the offer entered by the admin account. Each seller is referred to by a letter. No transcript, nothing a prospect said and no prospect's or seller's name goes into it. Only the admin account reads it. It is kept until the next generation, which replaces it, and deleted 30 days after a canceled Agency subscription ends; as it belongs to the team and not to a person, it is not included in the export of an account's data. In a team, each account's own offer analysis no longer updates on its own: it is run again by hand.
Company documents. The admin account of an active team can upload up to 10 documents describing its sales procedures: a typed text, or a Word (.docx) or PDF file. The file's text is extracted on receipt and only that text is kept: the file itself is stored nowhere. This text is sent to the analysis provider to draw up a team brief from it (a long document is first summarized, once). This brief is attached to the analysis of every call from a team account, admin account included, in the same transfer as the transcript; a short version is sent to the live suggestions provider during every live call from a team account. Only the admin account sees the documents and the brief; it can remove a document at any time, and the brief is then rebuilt without it. Documents and brief are deleted 30 days after a canceled Agency subscription ends. The documents and the brief are included in the export of the admin account's data.
By joining a team, the member expressly agrees that their account is managed by the admin account, and the acceptance screen states that the admin sees the reports of their calls. The acceptance is kept as evidence, with its date and the version of the accepted text.
The admin account can remove a member or delete their account. Each departure is recorded (dates of joining and leaving, reason). Their acceptance, departures, shares, comments received or written and contributions to the team's challenges are included in the export of their data, and their team data is deleted with their account.
Transfers Outside the European Union
Some of our service providers may process data outside the European Union. In such cases, these transfers are governed by Standard Contractual Clauses (SCCs) approved by the European Commission, in accordance with Article 46 of the GDPR, to ensure an adequate level of protection.
Hosting
ClosePeak's database is hosted within the European Union, in Ireland. Audio recordings and call processing are hosted in North America, with our host.
Data Retention
Your personal data is retained in accordance with the following rules:
Your GDPR Rights
In accordance with the GDPR, you have the following rights over your personal data:
We are committed to responding within one month.
If you believe your rights are not being respected, you have the right to lodge a complaint with the CNIL (French Data Protection Authority): www.cnil.fr.
Participant Consent
By using ClosePeak, the user expressly undertakes to inform all call participants that a recording and/or analysis is in place, and to obtain their prior and explicit consent before any recording takes place, in compliance with applicable regulations (in particular the GDPR and national laws governing the recording of communications).
ORBIS ML cannot be held liable for any use of ClosePeak in breach of these legal obligations.
No Sale of Data
ORBIS ML does not sell, rent, or transfer for consideration the personal data of its users to any third party. Data is shared only with the processors strictly necessary for the operation of the service, within the framework defined by this policy. In an Agency team, the admin account also sees its members' information described in the "Agency teams" section.
Contact & Questions
For any question relating to this privacy policy or your personal data:
privacy@closepeak.io