Customer Data Responsibilities

Last updated: 5 August 2026

1. Roles under the DPA

Inqelo processes inbound call audio, form submissions and other personal data on behalf of subscribing businesses. This document sets out the obligations of each subscribing business ("you", "your", or "the Subscriber") when using Inqelo's Services.

Where you determine the purposes and means of processing, you are the data controller and Inqelo is your data processor. Where you process Lead Data for your own client, you remain responsible for that controller's authorisations and Inqelo acts as your Sub-processor. Inqelo handles Lead Data only as instructed by you and under the Data Processing Agreement. The Privacy Policy applies to Inqelo's own account-holder data, not Lead Data.

Important: This policy is general information about how responsibility is divided between you and Inqelo. It is not legal advice and it is not specific to any jurisdiction. You should consult a qualified legal professional about the obligations that apply to you.

2. Your responsibility for lawful collection and instructions

As controller, or as a processor acting for your own client, you are responsible for:

Lawful Basis: Ensuring you have a lawful basis for collecting and processing the personal data of your customers, website visitors, and callers.
Transparency: Informing data subjects about the data you collect, how it is used, and who it is shared with, including the use of Inqelo as a data processor under the DPA.
Data Subject Rights: Responding to requests from data subjects to access, correct, or delete their personal data, using the tooling and obligations described in the DPA.
Consent (where required): Obtaining any required consent before collecting personal data, particularly for call recording and website tracking.
Instructions: Ensuring that the instructions you give Inqelo, including the data you send to the Services, comply with the law that applies to you.

3. Website and tracking responsibilities

The tracking functionality may process contact, attribution, device and interaction data as configured. Inqelo supports recognised consent signals and applies your configured privacy defaults. You configure your website, consent-management platform and notices, and you must:

Update your website's Privacy Policy to disclose the use of Inqelo's tracking technology and the data it collects.
Include Inqelo in your website's cookie consent notice (where applicable under GDPR, ePrivacy Directive, or equivalent legislation).
Clearly explain what data is collected, why it is collected, and how visitors can exercise their rights.
Configure your Consent Management Platform so that visitor choices are signalled to Inqelo where required.
Ensure your website forms include a clear statement about how submitted data will be used and stored, with a link to your Privacy Policy on or near the form.

You remain responsible for obtaining and signalling visitor consent as required by law. Current technical behaviour and supported consent frameworks are described in product documentation.

4. Calls and other communication recordings

Where call recording is enabled, call audio is stored by Inqelo in the EU and processed by Inqelo and its authorised Sub-processors for transcription and analysis.

Laws governing the recording, monitoring, transcription, storage, use and disclosure of calls and other communications vary by jurisdiction and may depend on your location and the location of each participant.

You determine whether and how communications are recorded, and you are responsible for identifying and complying with all laws that apply to you, to the communication and to its participants, including any notice, consent, opt-out, retention and disclosure requirements.

You warrant that you are legally entitled to provide any audio or recording to Inqelo and to instruct Inqelo to process it. Inqelo processes audio and recordings only on your documented instructions and in accordance with the Data Processing Agreement.

Inqelo does not provide jurisdiction-specific legal advice. Inqelo may refuse or suspend processing where it reasonably believes an instruction would infringe applicable Data Protection Legislation.

5. Integrations you configure

You decide which Customer-controlled advertising, analytics, telephony and other third-party accounts you connect to the Services. You are responsible for your agreements with those suppliers and for the lawful basis for the personal data they provide to the Services. Where Inqelo supplies or operates a provider as part of the Services, Inqelo is responsible for that provider under the applicable Agreement.

6. Data minimisation and retention

Data Minimisation: Ensuring that you only collect data that is necessary for your stated purposes, including through your website forms.
End of the Services: At your choice, Inqelo deletes or returns Lead Data at the end of the Services. If you make no election within 30 days after termination, Inqelo deletes it as stated in DPA clause 7.10.

7. Inqelo's processor responsibilities

Inqelo processes personal data on your behalf to provide the Services described in your subscription. In our role as data processor, we:

Process Lead Data only in accordance with your documented instructions and the DPA.
Implement appropriate technical and organisational security measures to protect personal data.
Do not sell Lead Data or use it for any independent purpose; disclose it to authorised Sub-processors only to provide the Services.
Provide appropriate functionality and reasonable assistance to support your response to applicable data-subject requests.

8. Changes to the policy

We may update this general guidance from time to time. When we do, we will update the "Last updated" date at the top of this page. This guidance does not amend or form part of the Terms of Service.

For material compliance changes, Inqelo sends a notice by email to every active account. These are required Service notices and do not have a separate subscription or opt-out.

9. Contact

If you have questions about these responsibilities, your obligations as a data controller, or Inqelo's role as a data processor, please contact us at:

JoPaJoEm Pty Ltd (ACN 125 834 184)
as trustee for the JoPaJoEm Family Trust (ABN 98 473 397 086)
trading as Inqelo
Email (Support): support@inqelo.com
Email (Billing): billing@inqelo.com
Email (Privacy): admin@inqelo.com
Address: 167 Flinders Street, Adelaide SA 5000, Australia