Privacy Policy

1 Who we are & the scope of this policy

Apps Bakery operates Crumb, an AI assistant that answers phone calls on behalf of small businesses, speaks with their callers, books meetings, and sends call summaries. Depending on the interaction, we play one of two roles:

• As a controller. When you visit the Site, submit a lead or contact form, or sign up as a Crumb customer, we determine how and why your personal information is processed. This Policy governs that processing.
• As a processor / service provider. When Crumb answers calls for one of our business customers, we process the personal information of that business's callers ("End Callers") on behalf of and under the instructions of that business, which is the controller of that data. In those cases, the business customer's own privacy policy governs, and our handling is set out in our customer agreement and Data Processing Addendum (DPA).

If you are an End Caller and have questions about how your information is used, please contact the business you called. We will assist that business in responding to your request.

2 Information we collect

a. Information you give us

• Contact & lead details — your name, email address, and (optionally) phone number when you submit a form on the Site or request a setup or call-back.
• Account & business information — if you become a customer: business name, role, services offered, business hours, scripts/greetings, calendar and scheduling preferences, and similar details needed to configure your Crumb.
• Billing information — billing contact and plan details. Card payments are handled by our third-party payment processor; we do not store full card numbers.
• Communications — the content of emails, messages, or other correspondence you send us.

b. Information we collect automatically

• Usage & device data — IP address, browser and device type, operating system, pages viewed, referring/exit pages, and date/time stamps.
• Cookies and similar technologies — see Section 7.
• Analytics & advertising signals — where enabled, aggregated and event-level data from tools such as Google Analytics, Microsoft Clarity (which captures anonymized heatmaps and session recordings of how the Site is used, with form fields masked), and advertising pixels (e.g., the Meta Pixel) to measure traffic and campaign performance.

c. Call data processed through the Crumb service

When Crumb handles a call, we may collect and process:

• Call audio recordings and transcripts of the conversation.
• Caller-provided details such as name, phone number, email address, the reason for the call, and appointment or booking information.
• Call metadata — phone numbers involved, time, date, and duration of the call.
• AI-generated summaries and outcomes that are sent to the business customer after each call.

For calls handled on behalf of a business customer, this data is processed under that customer's instructions (see Section 1).

3 Call recording & artificial intelligence

Crumb is an automated, AI-powered system. Calls handled by Crumb may be monitored, recorded, and transcribed, and the conversation is processed by automated language and voice models in order to understand the caller, respond, book meetings, and produce a summary.

• Notice and consent. Call-recording and one- or two-party consent laws vary by jurisdiction. Our business customers are responsible for ensuring that any legally required notice or consent is provided to their callers; we provide configuration options and notices to support this. Where we control an interaction directly, we provide appropriate notice.
• Automated decision-making. Crumb may take routine actions during a call (such as offering and confirming appointment times). It does not make decisions that produce legal or similarly significant effects about you without human involvement.
• Model use. Conversation content may be shared with AI/voice technology providers acting as our subprocessors solely to deliver the Service. Where we use data to improve our systems, we apply safeguards such as access controls and, where practical, de-identification or aggregation.

4 How we use information

We use personal information to:

• Provide, operate, maintain, secure, and improve the Site and the Services;
• Respond to inquiries, set up and run your Crumb, answer calls, and schedule meetings;
• Process transactions and send service and transactional communications (e.g., setup confirmations, call summaries, billing notices);
• Send marketing communications where permitted, from which you can opt out at any time;
• Measure and analyze traffic, usage, and advertising performance;
• Train, tune, and improve our voice and AI systems, subject to the safeguards described in Section 3;
• Detect, prevent, and address fraud, abuse, security incidents, and technical issues; and
• Comply with legal obligations and enforce our terms and agreements.

5 Legal bases for processing (EEA / UK)

If you are in the European Economic Area or the United Kingdom, we process your personal information on one or more of the following legal bases:

• Performance of a contract — to provide the Services you or your business request;
• Consent — for example, for certain marketing or non-essential cookies; you may withdraw consent at any time;
• Legitimate interests — to operate, secure, and improve our Services, where not overridden by your rights; and
• Legal obligation — to comply with applicable laws.

6 How we share information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising in a way that requires consent without offering you a choice. We disclose information only as described here:

• Service providers & subprocessors — companies that help us run the Services, such as cloud hosting, telephony/voice infrastructure, AI and speech-to-text providers, calendar and scheduling tools, CRM, email and SMS delivery, analytics, and payment processing. They may use the data only to provide services to us.
• Our business customers — End Caller information is made available to the business on whose behalf the call was handled.
• Legal, safety & compliance — when required by law, subpoena, or legal process, or to protect the rights, property, or safety of Apps Bakery, our users, or the public.
• Business transfers — in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.
• With your consent — for any other purpose disclosed to you at the time.

7 Cookies & tracking technologies

We and our partners use cookies, pixels, and similar technologies to operate the Site, remember preferences, measure performance, and (where enabled) support advertising. These generally fall into three categories:

• Essential — required for the Site to function;
• Analytics — help us understand how the Site is used; and
• Advertising — help us measure and improve campaigns.

You can control cookies through your browser settings; blocking some cookies may affect how the Site works. We do not currently respond to "Do Not Track" browser signals, as no common standard has been adopted.

8 Data retention

We keep personal information only for as long as necessary to fulfill the purposes described in this Policy, including providing the Services, complying with our legal, tax, and accounting obligations, resolving disputes, and enforcing our agreements.

• Lead and contact data is retained while we follow up with you and for a reasonable period afterward, unless you ask us to delete it sooner.
• Call recordings, transcripts, and summaries are retained in line with our agreement with the relevant business customer and applicable law.

When information is no longer needed, we delete or de-identify it.

9 Data security

We use reasonable technical and organizational measures designed to protect personal information, including encryption of data in transit, access controls, and limiting access to those who need it. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10 Your privacy rights & choices

EEA / UK residents

Subject to applicable law, you may have the right to access, correct, delete, restrict, or object to the processing of your personal information, to data portability, and to withdraw consent. You also have the right to lodge a complaint with your local data protection authority.

California residents (CCPA / CPRA)

Subject to applicable law, you may have the right to know and access the personal information we collect, to request deletion or correction, to opt out of the "sale" or "sharing" of personal information, and to limit the use of sensitive personal information. We do not sell your personal information. We will not discriminate against you for exercising your rights, and you may use an authorized agent to submit a request.

How to exercise your rights

Email us at crumb@appsbakery.net with your request. We will verify your identity and respond within the time required by applicable law. If your request concerns data we process on behalf of a business customer, we will refer you to, or work with, that business.

11 International data transfers

We are based in, and may process and store information in, the United States and other countries where we or our service providers operate. These countries may have data-protection laws that differ from those in your country. Where required, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, to protect personal information transferred across borders.

12 Children's privacy

The Services are intended for businesses and are not directed to children. We do not knowingly collect personal information from children under 16. If you believe a child has provided us with personal information, please contact us and we will take steps to delete it.

13 Third-party links & services

The Site and our communications may link to third-party websites and tools (for example, our scheduling provider). We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies.

14 Marketing & messaging choices

You can opt out of marketing emails at any time using the unsubscribe link in those emails, or by contacting us. We may still send you non-promotional, transactional messages related to your account or the Services. If you receive SMS messages from us, you can opt out by replying STOP; message and data rates may apply.

15 Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. If we make material changes, we will provide additional notice as appropriate. Your continued use of the Services after an update means you accept the revised Policy.