Ringtime BV
Frans Ackermanstraat 20, 9000 Gent, Belgium
Company Number: 1026.705.408
VAT Number: BE1026705408

Email: hello@ringtime.ai
Last updated: May 29, 2026

1. Identity and contact details of the data controller

This Privacy Policy applies to the processing of personal data by Ringtime BV, a private limited liability company incorporated under Belgian law, with registered office at Frans Ackermanstraat20, 9000 Ghent, Belgium, registered with the Crossroads Bank for Enterprises(CBE) under number BE 1026.705.408 (hereinafter “Ringtime”, “we” or “us”). Ringtime is the data controller of this website and is committed to protecting yourprivacy.

Ringtime processes personal data in accordance with the European General Data Protection Regulation 2016/679 of 27 April 2016 (hereinafter “GDPR”), as well as any future or additional legislation implementing or complementing the GDPR, to the extent applicable.

Depending on the context, Ringtime may act either as data controller, for example when processing personal data in relation to this website, demo requests, marketing activities, contractual relationships with customers and suppliers, or the management of its staff and contractors; or data processor, when processing personal data on behalf of its customers in the context of providing conversational AI services (e.g. voice ormessaging interactions with end users). Where Ringtime acts as a data processor, personal data is processed strictly in accordance with the instructions of the relevant customer, who acts as the data controller. In such cases, the applicable privacy information and data subject rights are governed by the privacy policy of the respective data controller.

If you have any questions or comments regarding this Privacy Policy or about how we handle your personal data, you can contact us by email at hello@ringtime.ai or by post at the address mentioned above.

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2. What does “processing personal data” mean?

For the purposes of this Privacy Policy, “processing of personal data” means any operation or set of operations performed on information relating to an identified or identifiable natural person.

An identifiable natural person is someone who can be identified, directly or indirectly, for example by reference to a name, contact details, online identifiers, or other information specific to that individual.

The concept of “processing” is broad and includes, among other things, the collection, recording, organisation, storage, use, consultation, transmission, sharing, anonymisation, or deletion of personal data.

Which categories of personal data are processed, and for which purposes, are further described in this Privacy Policy.

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3. Which personal data do we process?

Below we explain which categories of personal data may be processed by Ringtime. Depending on your relationship with us, the way you interact with us, and the context in which your data is processed, not all categories listed below will necessarily apply.

Core business activities (customers & end users)

As part of its core activities, Ringtime develops and provides conversational AI solutions (e.g. voice and messaging agents) for business customers. In this context, Ringtime may process personal data either as a datacontroller or as a data processor, depending on the situation.

When acting as a processor on behalf of customers, Ringtime may process the following categories of personal data of end users, strictly in accordance with customer instructions:

• Identification data (e.g. first name, last name)
• Contact details (e.g. phone number, email address)
• Conversation data generated during interactions (e.g. voice recordings and transcripts)
• Information provided during conversations (e.g. answers to screening questions, availability, preferences)
• Appointment-related or scheduling information
• Technical metadata related to the interaction (e.g.time stamps, call status)
• Communication preferences (e.g. newsletter subscription, language preference)
• Any information shared through our contact form orother communication channels (e.g. questions, feedback)
• In these cases, the customer acts as the data controller and determines the purposes andlegal bases of the processing. End users should consult the privacy policy of the relevant customer for more information.

Communication and commercial contracts

In the context of communication, sales, and business development activities, Ringtime may process personal data of individuals who contact us or engage with us via digital channels or professional networks.

This may include:

• Name and professional contact details (e.g. businessemail address, phone number)
• Company name and job title
• Communication preferences
• Information provided via contact forms, demo requests, email correspondence, or social media
• Interaction history related to sales or supportcommunications

Job applicants and contractors

If you apply for a position or collaborate with Ringtime as a self-employed contractor, we may process the following personal data:

• Identification data (e.g. name)
• Contact details (e.g. email address, phone number)
• Recruitment or collaboration-related information (e.g. CV, professional background, experience)
• Correspondence and interview notes
• Contractual and administrative data (if engaged)

Your application data will be kept for no longer than 2 years after the last meaningful contact, unless otherwise required by law or with your consent

Customers,suppliers and service providers

For the purpose of managing contractual and commercial relationships, Ringtime processes personal data of customer representatives, suppliers, and service providers, such as:

• Identification and professional contact data
• Company-related information
• Contractual and operational data
• Invoicing and payment information
• Communication and correspondence related to the business relationship
• Testimonials, feedback or contributions for publications or promotional materials

Website visitors

When visiting our website https://www.ringtime.ai, we may process certain personal data, including:

• IP address
• Browser type and device information
• Approximate location based on IP address
• Website usage data (e.g. visited pages, time spent)
• Data collected via cookies and similar technologies (see our Cookie Policy for more information)
• Data submitted via website forms (e.g. contact or demo request forms)

This data is used to operate the website, analyse usage, improve performance, andrespond to inquiries.

Photos and video material

Photos or video recordings may be created in the context of professional activities, events or marketing initiatives. Where applicable, consent is obtained for the use of such material for communication, marketing, or publication purposes. Consent can be withdrawn at any time.

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4. For what purposes do we process your personal data?

Ringtime processes personal data only for specific, explicit, and legitimate purposes and does not process more data than is necessary for those purposes. Depending on the context in which Ringtime acts as data controller or data processor, personal data may be processed for the following purposes.

When acting as a data processor, Ringtime processes personal data on behalf of its customers for the purpose of:

• Providing conversational AI services (e.g. voice and messaging interactions);
• Handling inbound and outbound communications with end users;
• Collecting and processing conversation data (audio and transcripts) as instructed by the customer;
• Ensuring the technical operation, quality, and reliability of the services.

In these cases, the customer determines the purposes and legal bases forthe processing.

When acting as a data controller, Ringtime processes personal data for the following purposes:

• Managing and maintaining relationships with customers, prospects, suppliers, and service providers;
• Responding to contact requests, demo requests, and other inquiries;
• Sales, marketing, and business development activities (primarily in a B2B context);
• Managing contracts, invoicing, accounting, and compliance with legal obligations;
• Recruitment and management of staff and self-employed contractors;
• Operating and improving the website and digital tools;
• Ensuring the security,integrity, and continuity of its systems and services;
• Creating communication and marketing materials (including photos or videos, where applicable).

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5. On what legal grounds do we process your data?

Ringtime processes personal data only where there is a valid legal basis under the GDPR. Depending on the processing activity, one or more of the following legal grounds apply:

 Legal obligation

Certain data is processed in order to comply with legal or regulatory obligations applicable to us. For example, tax and accounting requirements, or obligations related to data protection legislation.

Contractual necessity

Personal data is processed where necessary for the conclusion, performance, or termination of a contract, including service agreements with customers; contracts with suppliers and service providers; collaboration agreements with self-employed contractors; handling demo requests or other pre-contractual communications.

Legitimate interest

Certain data is processed based on our legitimate interest, which inspecific cases outweighs any potential impact on your rights. These interests include operating, maintaining and improving its services and infrastructure; ensuring network and information security; managing business relationships and internal administration; marketing and promoting its services in a professional B2B context; quality control, analytics, and service optimization (using anonymized or aggregated data where possible); establishing, exercising, ordefending legal claims.

Consent

Where required, personal data is processed based on the data subject’s consent. This may include, for example the use of non-essential cookies (e.g. analytics or marketing cookies); the use of photos or video material for communication or marketing purposes; receiving newsletters or marketing communications where an opt-in is required.

Consent can be withdrawn at any time, without affecting the lawfulness of processing carried out prior to the withdrawal.

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6. Source of the data

Most of the personal data we process has been provided directly by you. In the context of our operations, we may also receive your data via external service providers or from public sources, such as publicly available contact details or databases related to EU institutions or partners.

Most personal data processed by Ringtime is obtained directly from you, for example when you contact us via the website or request a demo; communicate with us by email or other channels; enter into a contractual relationship with us; or apply for a position or collaborate with us as acontractor.

When Ringtime acts as a data processor, personal data is typically provided by our customers, who act as the data controller, or is collected directly from end users during interactions as instructed by the customer.

In limited cases, personal data may also be obtained from publicly available sources (e.g. professional contact details published online); third-party service providers used in the context of our business operations (e.g. CRM or scheduling tools), always in accordance with applicable data protection laws.

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7. With whom do we share your data?

Ringtime does not disclose personal data to third parties unless this is necessary for the purposes described in this Privacy Policy, required by law, or permitted under the GDPR.

Where necessary, we engage external service providers (processors) to support our operational goals, such as managing our website, IT infrastructure, communication tools, or events. These processors may process your personal data on our behalf, but only to the extent required for the specific purpose. They are contractually bound by a data processing agreement to ensure the confidentiality and protection of your data and are not permitted to use your data for any other purpose.

Depending on your relationship with Ringtime, personal data may also beshared with:

• Professional advisers (e.g.accountants, legal advisers);
• Competent authorities, regulators or courts, where required by law;
• Banking and payment service providers for invoicing and payment processing.

When Ringtime acts as a data processor for its customers, personal data may be shared with sup-processors strictly necessary for the provision of the services. In such cases, data sharing is governed by the customer’s instructions and the applicable data processing agreement.

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8. How long do we keep your data?

We do not retain your data longer than necessary for the purposes for which it was collected or processed. Retention periods vary depending on the nature of the data and the context of the processing. In some cases, we are legally required to retain certain data for aminimum period (e.g., tax or financial records).

We always base our retention on legal obligations and a balanced consideration of your rights and expectations, and what is useful or necessary for achieving our legitimate goals. Once the retention period has expired, your data will be deleted or anonymised.

Where Ringtimeacts as a data processor, personal data is retained in accordance with the customer’s instructions and the applicable data processing agreement.

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9. Where do we store your data and how is it protected?

Personal data processed by Ringtime is primarily stored and processed within secure cloud environments provided by reputable service providers.

Ringtime implements appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data. These measures include, where appropriate, access controls, encryption, secure authentication, and the principle of least privilege.

Ringtime also ensures that any processorsor sub-processors acting on its behalf apply appropriate security measures and provide sufficient guarantees to protect personal data, in line with the GDPRand contractual obligations.

Where personal data is processed outside the European Economic Area (EEA), this will only take place in countries that are recognised by the European Commission as providing an adequate level ofdata protection; or where appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or other lawful transfer mechanisms under the GDPR.

Further information on international datatransfers and applicable safeguards can be obtained upon request.

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10. What are your rights?

You have several rights concerning the personal data we process about you. If you wish to exercise any of the rights listed below, please contact our GDPR contact person using the contact details mentioned in the first section of this Privacy Policy.

Right of access and copy

You have the right to access your personal data and to obtain a copy of it. This also includes the right to request further information about how we process your data, such as which categories of data we process and for what purposes.

Right to rectification

You have the right to request correction of your data if you believe that we hold incorrect or outdated information about you.

Right to erasure (right to be forgotten)

You may request that we erase your personal data without undue delay. However, this right is not absolute and maybe denied in certain cases—for example, if the data is still required for the performance of a contract, or if we are legally obliged to retain the data fora specific period.

Right to restrict processing

You may request that the processing of your data be restricted, for example, if there is uncertainty about the accuracy of the data. This means that the data will only be processed with your consent or under specific legal circumstances.

Right to withdraw consent

If your data is being processed based on your consent, you may withdraw that consent at any time by contacting us. For marketing emails sent based on your consent, you can easily unsubscribe by clicking the unsubscribe link provided at the bottom of each email.

Right to object

You have the right to object to the processing of your data that is based on our legitimate interest, for reasons related to your specific situation. You also have the right to object to theuse of your data for direct marketing purposes. In such cases, an opt-outoption will always be available in our communication.

Right to data protability

You have the right to receive your personal data, which you have provided to us with your consent or under a contract, in a structured, commonly used and machine-readable format. You also have the right to request the transfer of your data directly to another controller, where technically feasible.

Right to file a complaint with a supervisory authority

If you believe that your data is being processed in violation of the applicable data protection regulations, you always have the right to file a complaint with your national data protection authority.

Belgian Data Protection Authority (GBA)

Drukpersstraat 35

1000 Brussels

contact@apd-gba.be

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11. How can you exercise your rights?

You can exercise your rights by contacting us either by email at hello@ringtime.ai or by postal mail at Ringtime BV (t.a.v. DPO), Frans Ackermanstraat 20, 9000 Ghent, Belgium, accompanied by a copy of the front of your identity card or another identification document. This copy will only be used to verify your identity in accordance with the GDPR.

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12. Changes to this policy

We reserve the right to modify this Privacy Policy at any time. The most recent version is always available on our website. The date of the most recent change is shown at the top of this document. In the event of any substantial changes that may significantly impact the rights of data subjects, we will notify the affected individuals directly where possible.

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