This Privacy Policy explains how Viking Online Services Gromosław Czerski (“Viking Online”, “we”, “our”, “us”) collects, uses, processes, stores, and protects personal information in connection with our services, including our AI Receptionist, automation systems, consulting services, CRM systems, websites, and digital products.
We are committed to complying with the General Data Protection Regulation (GDPR), UK GDPR, Polish privacy law, and applicable global privacy regulations including CCPA where relevant.
If you do not agree with this Policy, you must not use our services.
1. Data Controller & Contact Details
Data Controller:
Viking Online Services Gromosław Czerski
Olimpów 62
39-124 Iwierzyce
Poland
NIP: 8181741223
EUVAT ID: PL8181741223
Under GDPR, Viking Online acts as:
Data Controller for our website visitors, marketing, billing, and internal operations.
Data Processor for Client Data processed through our AI systems, CRM integrations, phone systems, and automations.
2. Information We Collect
We collect personal information in the following categories.
2.1 Information Provided Directly by Clients
Business contact details
Email addresses
Phone numbers
Address and billing details
Payment information (processed by Stripe, never stored by us)
Onboarding information
Company scripts, FAQs, tone of voice, policies
Call handling instructions
CRM access tokens or API keys (encrypted where possible)
2.2 Information Captured by the AI Receptionist
As part of the AI Receptionist or conversational AI services, we may process:
Caller phone numbers
Call metadata (duration, timestamps, call direction)
Call recordings (if enabled by the client)
Call transcripts and summaries
Message history (SMS, WhatsApp, emails)
Appointment details
Customer notes and lead information
Website form submissions
Clients are responsible for obtaining legally required caller consent for recording or processing.
2.3 Information Collected Automatically
When using our website or CRM environments:
IP addresses
Browser type
Device information
Cookies
Usage analytics
Referrer URLs
Time spent on pages
2.4 Third-Party Integrations
We may process or transfer information through:
GoHighLevel (CRM, calendar, email, SMS)
Twilio (SMS, calls, A2P, call logs)
Stripe (payments)
Zapier or n8n (automations)
OpenAI or similar LLM providers (AI processing)
Google Workspace (email, calendar)
Notion (documentation)
Cloudflare (security & CDN)
AWS/Google Cloud (cloud hosting depending on AI model routing)
These tools may store or transmit data depending on their architecture.
3. Legal Basis for Processing (GDPR)
We process personal data under the following legal bases:
Contractual necessity – to deliver services to clients.
Legitimate interest – improving services, fraud prevention, analytics.
Legal obligation – tax, accounting, regulatory.
Consent – for call recording (client responsibility), cookies, marketing.
4. How We Use the Data
We use personal data to:
Provide and maintain the AI Receptionist
Process call flows, transcriptions, and automation
Route calls and messages
Process appointments
Deliver CRM integrations
Send system notifications
Improve AI performance
Conduct diagnostics, debugging, or support
Process payments and billing
Detect fraud or misuse
Comply with legal requirements
We do not:
Sell personal data
Use personal data for training general AI models (only ephemeral processing)
Share personal data with third parties unless required for service delivery
5. AI Processing
Our AI systems process caller interactions, messages, and instructions to generate responses.
We do not train models using client data unless explicitly permitted.
Data may be temporarily processed by:
OpenAI
Other LLM APIs
Internal AI pipelines
These providers act as sub-processors.
Clients must ensure any information provided to the AI does not violate:
GDPR
Local data protection laws
Confidentiality obligations
Professional ethics (law/medical/accounting)
6. Data Sharing & Sub-processors
We may share data with:
CRM providers (GoHighLevel, Clio, Pipedrive, HubSpot, Salesforce)
Communication carriers (Twilio, Plivo, Telnyx)
Cloud hosting providers (AWS, Google Cloud)
Payment processors (Stripe)
Automation tools (Zapier, n8n)
Analytics tools (GA4, Cloudflare)
Email service providers
All sub-processors are required to comply with data protection laws.
We do not share personal data with advertisers or unrelated third parties.
7. Data Retention
We retain data only as long as necessary for:
Contractual obligations
Legal compliance
Improving our services
Client instructions
Standard retention:
Call transcripts: up to 12 months unless the client requests deletion sooner
Call recordings: retained based on client settings
CRM data: stored according to client configuration
Billing records: 6 years per accounting law
AI logs: typically 30–90 days
Clients may request custom retention schedules.
8. International Data Transfers
Data may be processed in:
Poland
EU/EEA
United States
United Kingdom
When data leaves the EU, we implement:
Standard Contractual Clauses (SCCs)
Data Processing Agreements
Adequacy decisions where applicable
9. Data Security
We implement:
SSL/TLS encryption
Token-based authentication
Access restrictions
Encrypted API keys
Internal security protocols
Routine audits
Limited access to staff
However, no system is 100% secure.
By using our services, the Client acknowledges inherent risks.
10. Call Recording Compliance
If call recording is enabled:
The Client is responsible for notifying callers when required by law.
Viking Online provides infrastructure but does not provide legal advice.
The Client must comply with local regulations (including two-party consent jurisdictions).
11. Children’s Data
We do not knowingly collect data from children under 16.
Clients must ensure their use cases comply with child privacy laws.
12. Data Subject Rights (GDPR)
Individuals have the right to:
Access personal data
Correct inaccuracies
Request deletion (“right to be forgotten”)
Restrict processing
Object to processing
Data portability
Withdraw consent
Requests must be submitted via email.
We may request identity verification before fulfilling requests.
13. CCPA Rights (If Applicable)
California residents may request:
Disclosure of collected data
Deletion of data
Opt-out of data sharing
Non-discrimination in service delivery
14. Client Responsibilities
Clients must:
Provide lawful data
Obtain caller consent for recording
Configure compliant call flows
Avoid instructing the AI to engage in restricted topics
Comply with GDPR/TCPA/A2P rules
Ensure their customers are informed about AI use where required
Viking Online is not responsible for the Client’s legal compliance.
15. Automated Decision Making
The AI Receptionist may:
Route calls
Qualify leads
Generate responses
Book appointments
Send follow-up messages
These operations are automated and based on client-defined rules.
Clients must ensure this use is compliant with their jurisdiction.
16. Updates to This Policy
We may update this Privacy Policy at any time.
Updates become effective upon posting.
Continued use constitutes acceptance of the updates.
17. Contact for Privacy Matters
To request deletion, access, or correction of personal data:
Email: [email protected]
Address: Viking Online Services Gromosław Czerski, Olimpów 62, 39-124 Iwierzyce, Poland.
18. Acceptance
By using the AI Receptionist, website, CRM systems, or any Viking Online service, the Client acknowledges:
This Privacy Policy
The Terms & Conditions
Full responsibility for their own compliance
That AI and automation may process personal data on their behalf