Privacy Policy

At Newbula ("we," "us," or "our"), we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered voice communication platform and related services.

1. Information We Collect

1.1 Information You Provide

• Account Information: Name, email address, password, and organization details when you create an account
• Payment Information: Billing details, payment card information (processed securely through our payment providers)
• Voice Agent Configuration: Settings, preferences, and configurations for your voice agents
• Contact Lists: Phone numbers and contact information you upload for outbound calling campaigns
• Communications: Information you provide when you contact our support team or provide feedback

1.2 Information We Collect Automatically

• Call Data: Call recordings, transcripts, duration, timestamps, and call outcomes
• Usage Information: Features used, frequency of use, performance metrics, and interaction patterns
• Device Information: Browser type, operating system, IP address, and device identifiers
• Analytics Data: Aggregated statistics about platform usage and performance
• Cookies and Tracking: Session cookies, authentication tokens, and preference settings

1.3 Information from Third Parties

• OAuth Providers: Profile information from Google when you sign in using OAuth
• Integration Partners: Data synchronized from integrated third-party services you connect
• Public Sources: Publicly available information used to enhance our services

2. How We Use Your Information

2.1 Service Provision

• Process and manage voice calls through our platform
• Provide AI-powered conversation analysis and insights
• Generate transcripts and maintain call recordings
• Calculate risk assessments and MLR analysis for healthcare organizations
• Manage user accounts and authentication

2.2 Service Improvement

• Analyze usage patterns to improve platform features
• Train and improve our AI models (using anonymized data)
• Develop new features and functionalities
• Conduct research and analytics

2.3 Communication

• Send service updates, security alerts, and technical notices
• Respond to customer support inquiries
• Provide product updates and feature announcements (with your consent)
• Send billing and account-related communications

3. How We Share Your Information

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

3.1 Service Providers

• Cloud Infrastructure: AWS, Google Cloud for hosting and data storage
• Voice Services: Telephony and voice AI providers for call processing
• Payment Processing: Stripe, PayPal for secure payment handling
• Analytics: Services that help us understand platform usage
• Communication: Email service providers for transactional emails

3.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including:

• Court orders, subpoenas, or legal processes
• To protect our rights, privacy, safety, or property
• To investigate fraud or security issues
• To enforce our Terms of Service

3.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.

4. Data Security

We implement industry-standard security measures to protect your information:

• Encryption: All data is encrypted in transit using TLS/SSL and at rest using AES-256 encryption
• Access Controls: Role-based access controls and multi-factor authentication
• Regular Audits: Security assessments and vulnerability testing
• Data Centers: SOC 2 Type II certified data centers
• Employee Training: Regular security awareness training for all staff
• Incident Response: Established procedures for detecting and responding to security incidents

5. Data Retention

We retain your information for as long as necessary to provide our services and comply with legal obligations:

• Account Data: Retained for the duration of your account and up to 90 days after deletion
• Call Recordings: Retained according to your configured retention policy (default: 90 days)
• Transcripts: Retained for the duration of your account unless deleted earlier
• Analytics Data: Aggregated data may be retained indefinitely in anonymized form
• Legal Compliance: Some data may be retained longer if required by law

6. Your Rights and Choices

6.1 Access and Control

You have the right to:

• Access: Request a copy of your personal information
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your account and associated data
• Portability: Export your data in a machine-readable format
• Restriction: Limit how we process your information

6.2 Communication Preferences

• Opt-out of marketing communications through the unsubscribe link in emails
• Manage notification preferences in your account settings
• Disable cookies through your browser settings (may impact functionality)

6.3 Do Not Track

We currently do not respond to Do Not Track signals, but we limit tracking to essential functionality and analytics.

7. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place:

• Standard Contractual Clauses approved by the European Commission
• Compliance with Privacy Shield frameworks where applicable
• Ensuring recipients provide adequate data protection

8. Children's Privacy

Our services are not intended for children under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 18, we will delete it immediately.

9. California Privacy Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information
• Right to opt-out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising privacy rights

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. For significant changes, we may also notify you by email or through a prominent notice on our platform.

11. Text Messaging (SMS)

Clinics that use Newbula may send text messages to their patients, and patients may text their clinic back. If you have agreed to receive text messages from your clinic, the terms below apply. Full program terms are available at newbula.ai/sms-terms.

• No Sharing of Mobile Information: No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Your mobile phone number and your SMS opt-in consent will never be sold or shared.
• What You Receive: Appointment reminders, care follow-ups, administrative notices from your clinic, and replies from clinic staff in conversations you take part in.
• Message Frequency: Message frequency varies. It depends on your appointment schedule, the care your clinic is coordinating, and any conversation you start with them.
• Message and Data Rates: Message and data rates may apply, depending on your mobile plan.
• Opt-Out: Reply STOP to any message to stop receiving texts. You will get one confirmation, and nothing after that. Reply START to begin again.
• Help: Reply HELP, contact your clinic directly, or email support@newbula.ai.
• Consent Is Not a Condition of Care: You do not have to agree to text messages to be treated, to book an appointment, or to use any service. Opting out will never affect the care you receive.
• Not for Emergencies: Text messaging is not monitored around the clock. In an emergency, call 911 or go to the nearest emergency room.

11.1 How Patients Opt In

Patients agree to receive text messages in one of these ways: by signing their clinic's patient communications consent form at registration; by telling clinic staff verbally, which staff then record along with the date; or by texting the clinic's number first and starting the conversation themselves. Consent is recorded in the patient's record and can be withdrawn at any time.

11.2 Protected Health Information

Standard text messaging is not an encrypted channel. Messages can be read by anyone with access to the phone and may appear on a locked screen. Clinics using Newbula are instructed to keep clinical detail out of SMS and to use the secure patient app for anything sensitive. By agreeing to text messages you accept this risk, and you may withdraw that agreement at any time by replying STOP.

12. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us: