Privacy Policy

This Privacy Policy explains how DIMAR L.L.C-FZ, operating the Callugo brand, handles personal data when people visit callugo.com, register for or use our services, contact us, or communicate through phone numbers and AI-powered voice services operated using Callugo.

1. Who we are and how to contact us

Callugo is a brand operated by DIMAR L.L.C-FZ, a limited liability company registered in Dubai, United Arab Emirates (“Callugo”, “we”, “our”, or “us”).

Registered business address: Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates.

Website: https://callugo.com | Privacy inquiries: info@callugo.com | Telephone: +971 50 949 5451.

This Policy applies to Callugo websites, accounts, subscriptions, virtual phone numbers, cloud/PBX features, AI voice agents, trial or demo calls, support communications, and related services (collectively, the “Services”). A customer-specific agreement or data processing addendum may provide further information for business customers.

2. Our role: account data and customer call data

For information we collect to operate Callugo itself, such as account registration, billing records, service inquiries, security logs and direct marketing preferences, DIMAR L.L.C-FZ generally determines the purposes and means of processing and acts as the data controller (or equivalent role under applicable law).

For personal data processed within a business customer's call flows, address books, recordings, transcripts and AI agent instructions (“Customer Call Data”), the customer generally determines why and how the information is used. In those circumstances, the customer normally acts as the controller and Callugo provides processing services on its behalf, subject to applicable contracts and law. Some telecommunications carriers, number providers, payment processors and other partners may separately act as independent controllers for their own legal or operational purposes.

If you called a business using Callugo and wish to understand that business's use of your conversation or exercise rights over it, please contact the business you called first. You may also contact us at info@callugo.com and we will review or route your request, as appropriate.

3. Personal data we collect

Depending on how you interact with the Services, we may collect and process:

• Account and contact information: name, business name, email address, telephone number, account credentials, user roles, preferences, and communications with us.
• Verification and number-registration information: business registration records, billing address, identification or residency documents, and other details requested by telecom operators or regulators to allocate or maintain phone numbers. Only information required for the relevant service or compliance check is requested.
• Payments and subscription data: subscription tier, invoices, billing address, payment status, transaction references, refunds, tax-related information, and limited payment-method details made available by the payment processor. We do not ordinarily receive complete payment-card numbers when payments are processed through Stripe.
• Call and service metadata: caller and recipient numbers, call direction, start/end times, duration, routing information, call status, associated accounts or agents, system events, and service consumption records.
• Call content and AI data: audio streams, recordings where enabled, transcriptions, AI-generated replies, call summaries, detected topics or outcomes, voice-agent prompts and configurations, and other content provided during or in connection with a call.
• Website and technical data: IP address, browser and device details, operating system, approximate location derived from IP, login events, cookies, usage events, diagnostic information, and security records.
• Support and communications: emails, messages, support requests, issue descriptions, and files you choose to share with our team.

Please avoid sharing sensitive personal information (such as payment-card security codes, health records, biometric identifiers or government identifiers) within AI calls unless this is necessary, lawful, and the service is specifically configured and approved for that use.

4. How we obtain information

We obtain information directly from you or your organisation; from callers and people communicating through customer-configured phone numbers or AI agents; automatically from the website, systems and call infrastructure; and, where relevant, from payments, telecommunications, hosting, security, verification and AI service providers. We may also receive details from an account administrator who invites you to use the Services.

5. Why we process personal data

We use personal data only for reasonably necessary, specified purposes, including:

• To establish, administer and secure accounts; provision and maintain telephone numbers, PBX features, AI agents and related communications services; route and deliver calls; and provide requested functionality.
• To execute subscriptions, process payments and refunds, issue invoices, account for usage and collect amounts due.
• To complete identity and business verification, meet number-allocation requirements, respond to lawful requests and comply with telecommunications, tax, anti-fraud and other legal obligations.
• To provide customer support; investigate outages, errors, abuse or fraud; maintain service quality; and prevent unauthorised access.
• To administer product trials and demo calls, respond to inquiries, and communicate significant service, billing or policy changes.
• To conduct aggregated or appropriately de-identified product analytics and improve service reliability, performance and user experience.
• To send optional promotional communications where permitted and in accordance with your marketing choices.

Where the EU/EEA GDPR or UK GDPR applies, relevant legal bases may include performance of a contract, compliance with a legal obligation, our legitimate interests in providing, protecting and improving the Services, and consent where required (for example, certain marketing activities, cookies or call-recording practices). When we act as a processor, the customer is responsible for identifying and communicating its own lawful basis. Other legal regimes, including the UAE Personal Data Protection Law and Singapore Personal Data Protection Act, may apply different consent rules and exceptions.

6. Telephone calls, recording, transcription and AI agents

Callugo enables customers to configure virtual numbers, call routing, voice agents and related features. During a call, live audio may be transmitted through telecommunications infrastructure and, if an AI agent is enabled, to voice recognition, language model and speech synthesis providers in order to understand the caller and generate responses. Depending on settings, the Services may create and retain recordings, transcripts, summaries, call outcomes and diagnostics.

A caller may interact with an automated AI agent rather than a human. Customers must provide any legally required advance notice that an AI system is being used and must obtain any consent or other lawful authorisation required for recording, transcription, monitoring, automated outreach or the use of personal data. Call recording, caller identification and outbound calling rules differ across jurisdictions. Callugo customers are responsible for lawful use of the calling functionality they configure.

AI outputs may contain errors and are not necessarily verified by a person before delivery. Customers should not configure AI agents to make legally or similarly significant decisions about individuals without an appropriate legal basis, safeguards and additional notices where required.

Third-party AI providers may retain or use call-related information for platform operation, monitoring, quality improvement or model development according to the applicable contract and configuration. Retention, training restrictions and zero-data-retention options vary by provider and plan. Unless a particular protection is expressly confirmed for the service you purchase, you should not assume that all AI processing is zero-retention or excluded from model improvement.

7. When and with whom we share information

We may disclose information only as reasonably necessary for the purposes described above, including to:

• Telecommunications operators, number providers and carriers involved in number provisioning, call origination, call termination, routing, identity checks and regulatory compliance; this may include Sonetel where used.
• PBX/telephony technology partners that provide calling infrastructure and related management functions; this may include Digital Tide where used.
• AI voice and supporting infrastructure providers that process audio, text, model inputs and outputs, including Vapi where deployed, and its connected speech-to-text, language-model and text-to-speech providers.
• Payment service providers, including Stripe, for checkout, subscription billing, fraud checks, payment processing, refunds and related financial records.
• Hosting, storage, email, security, website analytics and customer-support providers, to the extent those services are actually used.
• Professional advisers, regulators, courts and other lawful recipients when disclosure is required by law, to protect rights and safety, or in connection with a corporate reorganisation.

We do not disclose customer call content to unrelated third parties for their own advertising purposes. Service providers may nevertheless process certain data for their own compliance or independent-controller obligations as described in their notices. The precise providers and countries involved may depend on the number, route, selected product and service configuration.

8. International processing and transfers

Callugo is operated from the United Arab Emirates and serves international customers. Personal data may be routed, accessed or stored in the UAE, Singapore, the United States, Europe or other countries where our telecommunications, payment, cloud and AI partners operate. This does not mean that a Singapore telephone number guarantees that the call data remains in Singapore.

Where the law requires safeguards for international transfers, we will implement applicable measures, such as contractual data protection obligations, appropriate transfer mechanisms and assessments or other legally recognised safeguards. These may include EU/EEA standard contractual clauses where relevant and comparable-protection measures for transfers governed by Singapore's PDPA. Country-specific hosting or transfer commitments apply only if separately agreed in writing.

9. How long we keep information

We retain personal data only for as long as required for the purposes for which it was collected, subject to service settings, applicable provider retention and mandatory legal obligations. In particular:

• Account and service administration data are normally retained while the account is active and for a further period where required to resolve disputes, enforce agreements or meet legal obligations.
• Invoices, payment and tax records are retained for the period required by applicable financial, tax and recordkeeping laws.
• Call metadata, audio recordings, transcripts, AI logs and summaries are retained in accordance with the relevant service configuration, customer instructions, applicable technical limits and legal requirements. Different services or providers can have different retention periods.
• Support and security records are retained for the time reasonably necessary to manage requests, investigate incidents, protect the platform and comply with law.

After the relevant period, we delete, anonymise or securely restrict the information, unless further retention is legally required. Deleted information may remain in protected backups for a limited backup cycle. Customers can contact info@callugo.com to request available service-specific retention details and deletion options.

10. Cookies and website analytics

Our website may use essential cookies and comparable technologies for security, login, account sessions, fraud prevention and basic functionality. If analytics, personalisation or advertising tools are deployed, they may use additional cookies or similar identifiers to understand website activity.

Where legally required, we will obtain consent before using non-essential cookies and provide a way to change or withdraw that choice. You may also control cookies through browser settings, although disabling essential cookies can affect website functionality. If a separate cookie notice or preference centre is provided, it describes the actual cookies in use.

11. Security of personal data

We seek to apply appropriate technical and organisational safeguards proportionate to the sensitivity of the data and the risks involved. These may include user-access restrictions, authentication controls, secure transmission, logging, service-provider due diligence and incident-handling procedures. No internet-based system can be guaranteed to be completely secure. Customers are responsible for protecting their account credentials, assigning permissions appropriately and avoiding unnecessary disclosure of sensitive data through their configured workflows.

12. Your privacy rights and choices

Depending on your location, the nature of the information, and the law that applies, you may have rights to request access to personal data, correction of inaccurate data, deletion, restriction or objection to processing, portability where available, withdrawal of consent, and information about processing or disclosures. Some requests are limited by statutory exemptions or conflicting legal duties.

To make a request, write to info@callugo.com with "Privacy Request" in the subject line and enough information to locate the relevant account or communication. We may ask you to verify your identity before responding. Where a business customer controls the relevant call data, we may refer the request to that customer or assist the customer under our contractual duties.

You can unsubscribe from promotional emails using the unsubscribe option where provided, or contact us. Unsubscribing does not stop operational, billing or security communications.

Where applicable, you may complain to a competent data protection authority, including the Personal Data Protection Commission in Singapore or an EU/EEA supervisory authority. We encourage you to contact us first so we can examine your concern.

13. Children and sensitive information

Callugo account services are intended for adults and authorised business users, not for children to register independently. We do not intentionally market account subscriptions to children. Calls handled by a customer may nonetheless include information about a minor; in such cases the customer must ensure appropriate notices, authorisation and safeguards. Contact us if you believe personal data relating to a child was collected inappropriately through a Callugo-controlled interaction.

14. Data incidents and legally required disclosures

If we become aware of a security incident involving personal data, we will investigate and take steps appropriate to the circumstances. We will notify affected customers, individuals and regulators where and within the periods required by applicable law and our contractual obligations. We may also disclose information to comply with valid legal obligations, safeguard rights, prevent harm or respond to misuse of the Services.

15. External services and changes to this Policy

Third-party websites or applications linked from Callugo are governed by their own privacy notices. The use of external payment pages and some third-party communications functions may involve separate processing by those providers.

We may revise this Privacy Policy to reflect new services, vendors, legal requirements or processing practices. The current version will be published on our website with an updated effective date, and we will provide additional notice of material changes when the law requires it.

16. Privacy contact and company details

Brand: Callugo

Legal entity: DIMAR L.L.C-FZ

Registered address: Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates

Privacy and data protection inquiries: info@callugo.com

Phone: +971 50 949 5451

Website: https://callugo.com

Please use the email address above for questions about this Policy, data subject requests and complaints. The same contact channel is publicly available for data protection inquiries, including those from individuals in Singapore.