PRIVACY & COOKIE POLICY

Last Updated: 19/11/25 

1. Introduction 

These Terms of Service (“Terms”) govern the access and use of the voice automation and AI-enabled call handling services (“Services”) provided by Reqo SAS (“Reqo”, “we”, “us”, or “our”) to business clients (“Client”, “you”, “your”). 

By accessing or using the Services, you confirm that you have read, understood, and agreed to these Terms. These Services are offered exclusively to businesses and professional users, not for personal or consumer use. 

2. Definitions 

“Client Data”: Any data, including caller or reservation information, provided or generated through use of the Services. 

“Services”: AI-enabled voice assistants, call handling tools, transcription, reservation routing, automation workflows, dashboards, and integrations provided by Reqo. “Controller”: The entity which determines purposes and means of processing Personal Data (the Client). 

“Processor”: The entity processing Personal Data on behalf of the Controller (Reqo). “Sub-Processor”: A third party engaged by Reqo to help deliver the Services (e.g., hosting, AI processing, SMS, telephony). 

“DPA”: Data Processing Agreement attached as Annex 1 to these Terms, governing Personal Data processing under GDPR. 

3. Service Description 

Reqo provides AI-powered voice assistants that handle incoming calls, convert speech into text-based transcripts, collect reservation information, and deliver structured outputs to reservation and messaging systems. Reqo does not store or process call audio; only transcripts and metadata are maintained. 

The Services may integrate with third-party systems (scheduling, CRM, reservation platforms, SMS/email). Reqo is not responsible for the performance or availability of those external services. 

4. Use of the Services 

Clients must: 

● Provide accurate business information, opening hours, policies, and routing rules.

● Comply with all applicable laws, including GDPR, telecom, e-privacy, marketing, caller consent, and data protection. 

● Avoid submitting or requesting processing of payment data, health data, minors’ data, or special category data. 

● Ensure caller-facing disclosures, where required, indicating that their calls may be handled via automated systems. 

5. Data Protection and GDPR Compliance 

Where Reqo processes Personal Data on behalf of the Client, the Client is the Data Controller and Reqo is the Data Processor in accordance with GDPR and UK GDPR. 

Some infrastructure and data processing components used to deliver the Services are located in the European Union and the United Kingdom. Certain processing operations (such as speech-to-text conversion, infrastructure hosting, and routing services) may take place in the United States or other third countries. 

Where such transfers occur, Reqo ensures appropriate safeguards as required by GDPR and UK GDPR, including Standard Contractual Clauses (SCCs), encryption, access controls, and data minimisation. No call audio, biometric data, or special-category data is transferred. 

The Data Processing Agreement (DPA), incorporated as Annex 1 to these Terms, applies to all processing of Personal Data performed by Reqo. The Client confirms that it has the necessary legal basis to process Personal Data through the Services. 

Reqo will process Personal Data only under the Client’s instructions, and only to the extent necessary to deliver the Services. 

When handling calls on behalf of the Client, Reqo uses automated virtual assistants. Callers are informed at the beginning of the call that an AI assistant is responding and that a text transcript may be generated to help process their request. Callers may request human assistance at any time. This complies with GDPR, UK GDPR, CNIL, ICO, and EU AI Act transparency requirements. 

6. Intellectual Property 

Reqo retains all rights, title, and interest in and to the Services, including all software, documentation, workflows, prompt structures, analytics, and business logic, except for Client Data. 

The Client receives a non-exclusive, non-transferable, limited right to use the Services during the subscription term. The Client may not copy, reverse-engineer, resell, or provide external access to the underlying technology. 

7. Acceptable Use Restrictions

Clients must not: 

● Attempt to reverse engineer, replicate, or extract AI or telephony workflows. ● Collect special category data or biometric data through the Services. ● Use the Services for marketing spam or unlawful communications. ● Operate call center or emergency services (e.g., 112, 999, 911). 

Reqo may suspend access immediately in case of misuse or breach. 

8. AI Accuracy and Limitations 

The Services use automated speech recognition and AI-based tools to interpret caller inquiries. While designed for accuracy, outputs may contain errors, misunderstandings, or misinterpretations. 

The Client is responsible for verifying all AI-generated reservation details, caller information, and conversation outcomes before acting on them. 

Reqo does not guarantee 100% accuracy of reservations, transcriptions, or caller intent classification. 

9. Service Availability 

Reqo strives for reliable and secure Services but does not guarantee uninterrupted availability. Services may be affected by: 

● Hosting provider interruptions 

● Carrier and telecom issues 

● Internet disruptions 

● Maintenance or updates 

● Third-party system outages (e.g., CRM, reservation platforms) 

No service level guarantee applies unless separately agreed in writing. 10. Fees and Billing 

Fees, billing frequency, payment terms, and subscription renewal conditions are set out in the Order Form or plan configuration.

Unless otherwise stated: 

● Subscriptions renew automatically 

● Usage-based fees are billed periodically 

● Taxes and VAT are excluded unless explicitly stated 

Late payments may result in suspension of the Services. 

11. Limitation of Liability 

To the fullest extent permitted by law: 

● Reqo is not liable for indirect, incidental, or consequential damages (loss of bookings, revenue, business interruption, reputation). 

● Reqo’s total liability in any 12-month period shall not exceed the total fees paid by the Client in that same period. 

● Nothing in these Terms excludes liability for fraud or willful misconduct. 

12. Term and Termination 

These Terms apply from initial activation of Services and remain in effect unless terminated as per subscription agreement. 

Either party may terminate for material breach if not remedied within 30 days of written notice. Upon termination, the Client’s access will cease and data will be deleted or returned as per Annex 1 (DPA). 

13. Confidentiality 

Both parties agree to maintain confidentiality of each other’s non-public information, including business, technical, and customer-related data. 

14. Governing Law and Jurisdiction 

● Clients in the European Union: governed by French law; exclusive jurisdiction of the courts of Paris. 

● Clients in the United Kingdom: governed by English law; exclusive jurisdiction of the courts of London.

ANNEX 1 — DATA PROCESSING AGREEMENT (DPA) Last Updated: 19/11/25 This Data Processing Agreement (“DPA”) forms part of the Terms of Service between Reqo SAS (“Reqo” or “Processor”) and the Client (“Client” or “Controller”). 

1. Purpose and Scope 

This DPA governs the Processing of Personal Data by Reqo on behalf of the Client as required to deliver the Services. It ensures compliance with GDPR, UK GDPR, and other applicable data protection laws. Reqo will only process Personal Data on the documented instructions of the Client. 

2. Roles of the Parties 

● The Client is the Data Controller and determines the purposes and means of Processing. 

● Reqo is the Data Processor and processes Client Data solely for the provision of Services. 

● Reqo may engage authorized Sub-Processors as detailed in Section 7. 

3. Categories of Personal Data 

Reqo processes only limited, non-sensitive Personal Data, including: 

● Caller name or contact details (if provided) 

● Phone number or email address (if provided voluntarily) 

● Reservation request details (date, time, party size, comments) 

● Text-based transcripts of caller interactions (no audio recordings) 

● Call metadata (timestamps, routing status, conversation summaries) 

Reqo does not process: biometric data, audio recordings, payment card data, special category or sensitive data. 

4. Types of Data Subjects 

● Callers to the Client’s business 

● Restaurant and hotel guests making inquiries or reservations 

5. Nature and Purpose of Processing

Reqo processes Personal Data solely to provide AI-enabled voice services, including: ● Transcribing calls (text only) 

● Capturing reservation requests and contact details provided by callers ● Structuring data for reservation platforms, emails, or internal notifications ● Routing messages and call outcomes to Client personnel 

● Generating anonymized usage analytics (non-identifiable) 

Processing is strictly limited to the Client’s instructions. 

6. Client Instructions 

Reqo shall process Personal Data only: 

(a) as necessary to deliver the Services, 

(b) according to this DPA, and 

(c) in line with documented instructions from the Client. 

Reqo will not use Client Data for marketing, profiling, selling, or AI model training. 7. Sub-Processors 

Reqo uses third-party providers to deliver infrastructure, hosting, AI transcription, SMS/email delivery, and telephony connectivity. These Sub-Processors are bound by confidentiality and GDPR Article 28 obligations. 

A list of sub-processor categories is available on request. 

The Client may reasonably object to new Sub-Processors within 15 days of notification if a real data protection risk is shown. 

8. International Transfers 

If Personal Data is transferred outside the EU/UK, Reqo ensures appropriate safeguards, including: 

● Standard Contractual Clauses (SCCs) 

● Contractual confidentiality obligations 

● Encryption and access controls 

No special-category or biometric data is processed or transferred. 

9. Security Measures

Reqo will apply technical and organizational measures appropriate to the level of risk, including: 

● Encryption in transit and at rest 

● Access controls and authentication 

● Logging and monitoring 

● Secure hosting with privacy safeguards 

● Incident response procedures 

● Personnel confidentiality training 

10. Assistance with Data Subject Rights 

If a Data Subject requests access, deletion, correction, or portability, Reqo will assist the Client in fulfilling these rights as required by GDPR, but will not respond directly to individuals without Client authorization. 

11. Personal Data Breach Notification 

In the event of a confirmed breach affecting Personal Data, Reqo shall: 1. Notify the Client without undue delay 

2. Provide available information on the nature and scope of the breach 3. Assist with notifications to authorities or affected individuals, where required 

12. Data Retention and Deletion 

Reqo will retain Personal Data only for the period defined by the Client (typically 30–180 days). 

At Client request or upon termination of the Agreement, Reqo will securely delete or return Personal Data, unless legal retention is required. 

13. Audits 

Reqo will maintain documentation demonstrating compliance with this DPA. Upon reasonable request, Reqo will provide relevant information and may allow limited audits, subject to confidentiality and once per 12 months. 

14. Liability

Liability under this DPA is subject to the limitations agreed in the main Terms of Service. This DPA does not expand or modify either party’s liability. 

15. Term and Termination 

This DPA remains in effect for as long as Reqo processes Personal Data on behalf of the Client. Upon termination of the Services, Reqo will return or delete Personal Data in accordance with Clause 12. 

16. Contact 

For data protection matters: privacy@reqo.ai 

Reqo SAS, 61 Rue de Lyon, 75012 Paris, France