Privacy Policy

Scope of this policy

ToniAgent operates two distinct services, with different processing and different roles under the GDPR. Part 1 covers this website, toniagent.com, where Productivity Agents SL is the data controller. Part 2 covers the ToniAgent platform at app.toniagent.com, including the Google Calendar integration, where we act as data processor on behalf of the clinic that contracts the service. Read the part that applies to you.

Part 1 — The toniagent.com website

Data controller

The data controller for your personal data is ToniAgent. You can contact us through our contact form for any questions related to the processing of your data.

Data we collect

We collect personal data that you voluntarily provide through our contact forms, including name, email, phone, and any additional information you choose to share.

Purpose of processing

Your data will be used to: respond to your inquiries and requests, send you information about our services if you have given your consent, manage the business relationship, and comply with legal obligations.

Legal basis

The processing of your data is based on: your consent, the execution of a contract or pre-contractual measures, the legitimate interest of ToniAgent, and compliance with legal obligations.

Data retention

Your data will be kept for the time necessary to fulfill the purpose for which it was collected and to comply with applicable legal obligations.

User rights

You have the right to access, rectify, delete, limit, or object to the processing of your data, as well as data portability. You can exercise these rights by contacting us through our contact form.

Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or destruction.

International transfers

Your data may be transferred to service providers located outside the European Economic Area. In such cases, we ensure that appropriate safeguards exist in accordance with GDPR.

Part 2 — The ToniAgent platform and Google user data

This part applies if you use the ToniAgent platform or connect a Google account to it. It is reproduced from the Terms of Service, Privacy Policy and DPA accepted by our clients, and describes how the platform accesses, uses, stores, shares and deletes Google user data.

ToniAgent's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Reproduced from the ToniAgent platform legal instrument, version 2.1.3. The binding text is Spanish.

This Privacy Policy describes how Productivity Agents SL ("the Company", "ToniAgent", "we") collects, uses, stores and shares personal information.

It is addressed to two distinct audiences: control panel users (the clinic staff who sign in to ToniAgent), and users of the Google Calendar integration. Patient data is processed on behalf of the clinic and is governed by the DPA, not by this policy.

0. Control Panel Users

This section describes what we process about you as a control panel user, with the Company acting as controller.

Account data

First name, surname, email address, role, associated clinic, and registration data (IP address and sign-up date, kept as evidence of acceptance of these Terms). Legal basis: performance of the contract. Retained for as long as the account is active.

What the control panel stores in your browser

• Session and language: the AWS Cognito sign-in tokens, your language and your theme (light or dark). These are strictly necessary for the panel to work and do not require consent.
• Surveys: if we show you a survey inside the panel, your browser remembers (in local storage) which ones you have answered or dismissed, solely so that they are not shown to you again.

We do not use advertising, profiling or cross-site tracking cookies.

Enabled features and panel usage

The panel uses PostHog (EU servers) to:

• check which features are enabled for your clinic and for your account;
• measure how the panel is used: pages visited, time spent on each and actions on the interface (clicks, form submissions and navigation);
• replay the usage session, with all text, attributes and form fields masked: what is transmitted is the structure of the interface and the navigation, not the content you see or type. Recording pauses on pages whose address contains a phone number, and page addresses are sent without search parameters and without that number;
• occasionally show you short surveys inside the panel.

This information is associated with your internal user identifier, your clinic identifier and your email address. Except as described for surveys, it stores nothing on your device, and it does not affect patient data.

It is carried out on the basis of the Company's legitimate interest in deciding which features to show you and in understanding and improving how the panel is used (Art. 6(1)(f) GDPR), having weighed that content is masked before it leaves your browser, that it is not used for advertising or disclosed to third parties other than the processor, and that it is limited to your activity as a panel user.

You may object at any time to usage measurement, session replay and surveys, without having to give a reason and with no consequence for the service, by writing to privacy@toniagent.com. The check of enabled features is necessary for the panel to work and is kept.

Performance monitoring

We record panel errors and load times in order to detect and fix faults, together with your IP address, browser type and internal user identifier. The provider is New Relic (EU servers).

This monitoring stores nothing on your device: it uses neither cookies nor local storage. It is carried out on the basis of the Company's legitimate interest in keeping the service stable and secure (Art. 6(1)(f) GDPR), having weighed that it is limited to technical data, is not used for profiling or advertising, and does not affect patient data.

You may object at any time, without having to give a reason and with no consequence for the service, from the Privacy page of the panel. When you do so, the monitoring agent stops loading.

Who we share this data with

With the providers that operate the panel, acting as processors: AWS (hosting, EU), PostHog (enabled features and panel usage, EU), New Relic (monitoring, EU), and AWS Cognito (authentication, EU). For the clinic's invoicing, with Stripe and Holded in accordance with clause 4.4.

Your rights

You may exercise your rights of access, rectification, erasure, objection, restriction and portability by writing to privacy@toniagent.com . You may also lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

1. Google Calendar Integration

This section applies only if you choose to connect your Google Calendar account to ToniAgent. If you do not connect it, we do not access any data in your Google account.

If you choose to connect it, we access the following Google user data through the Google Calendar API:

OAuth Scopes Requested:

• calendar.readonly: Read-only access to your list of calendars and events.
• calendar.events: Read/write access to calendar events (used to read events and for the AI agent to book and cancel appointments on your behalf).
• userinfo.email: Your Google account email address.

Specific Data Collected:

1. Google Account Information:

Your Google email address (used to identify and associate your Google Calendar with your ToniAgent account).

2. Calendar Metadata:

Calendar IDs and names, calendar descriptions, time zone settings, calendar colours (background and foreground), primary calendar indicator.

3. Calendar Events:

Event titles (summary), event descriptions, event locations, start and end times (including all-day event indicators), event status (confirmed, tentative, cancelled), organiser email addresses, attendee information (email addresses and response status), recurrence rules (for recurring events), links to events in Google Calendar.

Data Accessed by the AI Agent:

When you interact with the ToniAgent AI assistant for calendar management, the AI agent processes:

• Your voice or text instructions about calendar operations (e.g. "Book a meeting with Juan tomorrow at 3 PM").
• Your existing calendar events, to check availability and avoid scheduling conflicts.
• Event details you provide (meeting titles, attendee names/emails, locations, descriptions).
• Confirmation responses for calendar operations.

This data is processed in order to carry out your calendar management requests and is subject to the same security and privacy protections as other Google Calendar data.

2. How We Use Your Google Calendar Data

We use your Google Calendar data for the following purposes:

1. Displaying Calendar Events:

Showing your calendar events within the ToniAgent application interface so that you can see your schedule alongside your other tasks and activities.

2. Local Synchronisation:

Synchronising and storing your calendar events locally in our database for faster access and better performance. This lets you view your calendar without repeated calls to the Google API.

3. Event Notifications (Optional):

If enabled, we configure webhook notifications from Google Calendar to receive real-time updates when your events change, keeping your synchronised events up to date.

4. Calendar Management by the AI Agent:

When you interact with the ToniAgent AI assistant, the agent may carry out the following actions in your Google Calendar on your behalf and with your explicit authorisation:

• Create new calendar events (book appointments): When you ask the AI agent to schedule a meeting or appointment, it will create a new event in your connected Google Calendar with the details specified (title, date, time, attendees, location, description).
• Cancel existing events: When you ask the AI agent to cancel an appointment, it will update the event status to "cancelled" or delete the event from your Google Calendar.
• Modify event details: When you request changes to an existing event (time, location, attendees), the AI agent will update the event in your Google Calendar.

How AI Agent Modifications Work:

• The AI agent only makes changes when you explicitly instruct it to (e.g. "Book a meeting with Juan tomorrow at 3 PM" or "Cancel my 2 PM appointment").
• All AI agent actions are performed using your authenticated OAuth tokens, which means changes are made as if you had made them yourself.
• You will receive confirmation of calendar modifications through the ToniAgent interface.
• All events created, modified or cancelled are reflected immediately in your Google Calendar and in any other application connected to it.

Important Safeguards:

• Your calendar data is isolated to your account and cannot be accessed by other ToniAgent users.
• The AI agent can only access calendars that you have explicitly connected to ToniAgent.
• We do not use your Google Calendar data for advertising or marketing, or to train artificial intelligence models.
• You retain full control and may revoke ToniAgent's access to your Google Calendar at any time.

3. How We Store Your Google Calendar Data

Database Storage:

Your Google Calendar data is stored in a PostgreSQL database hosted on Amazon Web Services (AWS) in the Ireland region (eu-west-1). We store three types of data:

• Google Account Information: Your Google email address and OAuth tokens (encrypted).
• Calendar Metadata: Calendar names, settings and synchronisation status.
• Calendar Events: Event details, times, attendees and descriptions.

Encryption and Security:

• OAuth tokens (access tokens and refresh tokens) are encrypted at rest using Fernet encryption with AES-256 before being stored in our database.
• Encryption keys are stored securely in AWS Secrets Manager and are never exposed in application code or logs.
• Calendar event data (titles, descriptions, attendees) is stored unencrypted for performance reasons, but access is restricted to authenticated users only.
• All data transmission between your browser, our servers and Google's servers uses HTTPS/TLS 1.2 or higher.

Data Isolation:

• Your Google Calendar data is associated exclusively with your user account.
• Our application enforces strict authorisation controls to ensure that users can only access their own Google Calendar data.
• Administrative users cannot override these controls to access other users' Google Calendar data.

Data Retention:

• Your Google Calendar data is retained for as long as your calendar integration is active.
• When you disconnect your Google Calendar account, we immediately and permanently delete all associated data, including: OAuth tokens, calendar metadata, and all synchronised events (both events created by you and events created by the AI agent on your behalf).
• This deletion is automatic and cascades throughout our database schema.

Important Note About AI-Created Events:

• Events created by the AI agent in your Google Calendar remain in your Google Calendar even after you disconnect ToniAgent. These are your calendar events.
• To remove AI-created events from Google Calendar, you must delete them directly in Google Calendar (either before or after disconnecting ToniAgent).
• Disconnecting ToniAgent only deletes our local copy of the synchronised event data, not the events themselves in Google Calendar.

4. Sharing Your Google Calendar Data

Infrastructure Provider:

We use Amazon Web Services (AWS) as our hosting and database provider. Your Google Calendar data is stored on AWS servers located in the Ireland region (eu-west-1) within the European Economic Area (EEA). AWS acts as a data processor under our Data Processing Agreement (DPA) and is subject to AWS's GDPR-compliant terms.

Derived data received by the voice agent:

To handle a call, the voice agent needs to know which slots are free and, if the caller asks about their own appointment, whose name it is under. Therefore, while the integration is active:

• The availability derived from your calendar (which time ranges are busy, without the event's title or content) determines the slots the agent offers.
• The name associated with an appointment, extracted from the event title by a text rule (not an AI model), may be returned to the agent when the patient asks about their own appointment.

This derived data is processed by ElevenLabs (the voice agent platform) and by the language models it uses, as well as by Amazon Bedrock in the post-call analysis, with language models AWS runs within the EU. None of these providers uses this data to train their models; see clause 5bis of the DPA.

What is not shared:

We do not transfer the full content of your events to those providers: neither the titles, nor the descriptions, nor the attendees, nor the names of your calendars. We do not share your Google Calendar data with advertising networks or marketing platforms, and we do not use it to train artificial intelligence models.

Google as a Data Source:

• When you connect your Google Calendar, you grant ToniAgent permission to access your Google Calendar data through Google's OAuth 2.0 authorisation.
• We access your Google Calendar data using Google's official Calendar API.
• Your relationship with Google and their use of your data is governed by Google's Privacy Policy, available at policies.google.com/privacy .

Compliance with the Google API Services User Data Policy:

ToniAgent's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. In particular: we only use Google Calendar data to provide and improve ToniAgent's user-facing features; we do not transfer it to third parties except to provide those features (the providers named in this policy), for security purposes, to comply with applicable law, or with your consent; no human reads it except with your consent, for security purposes, to comply with applicable law, or in aggregated and anonymised form; and we do not use it for advertising or to train or develop generalised artificial-intelligence or machine-learning models.

5. How the AI Agent Accesses Your Google Calendar

AI Agent Capabilities:

When you authorise ToniAgent to access your Google Calendar, our AI assistant can perform calendar management tasks on your behalf, including:

• Reading Your Schedule: The AI agent can view your calendar events to check your availability when scheduling appointments or answering questions about your schedule.
• Creating Events: When you instruct the AI agent (e.g. "Schedule a meeting with Juan on Friday at 2 PM"), it will create a new event in your connected Google Calendar, set the event title, date, time, location and description according to your instructions, add attendees if specified, and send calendar invitations through Google Calendar.
• Cancelling Events: When you instruct the AI agent (e.g. "Cancel my 3 PM meeting tomorrow"), it will find the corresponding event in your calendar, update the event status to "cancelled" or delete the event, and Google Calendar will notify attendees of the cancellation.
• Modifying Events: When you instruct the AI agent (e.g. "Move my meeting to 4 PM"), it will update the event details in your Google Calendar and Google Calendar will notify attendees of the changes.

Important Safeguards:

• The AI agent only acts on your explicit instructions — it will not create, modify or cancel events autonomously without your direction.
• All calendar operations are performed using your authenticated OAuth credentials, which means changes appear as if you had made them yourself in Google Calendar.
• The AI agent can only access calendars that you have explicitly connected to ToniAgent.
• You will receive confirmation of any calendar change through the ToniAgent interface.
• All modifications are synchronised immediately with your Google Calendar and are visible across all your devices and applications.

User Control:

• You may disconnect Google Calendar at any time to revoke the AI agent's access.
• You may select which specific calendars to share with ToniAgent (e.g. share your work calendar but not your personal calendar).
• You may review and manually modify any event created by the AI agent directly in Google Calendar.

6. Your Rights Regarding Google Calendar Data

You have full control over your Google Calendar integration:

Revoke Access at Any Time:

You may disconnect your Google Calendar account from ToniAgent at any time through the Integrations page in your account settings. Disconnecting will immediately delete all OAuth tokens, calendar metadata and synchronised events from our database.

Granular Control:

You may choose which specific calendars to synchronise with ToniAgent. You may disconnect individual calendars while keeping other calendars connected.

Google Account Settings:

You may also revoke ToniAgent's access to your Google Calendar directly through your Google Account settings at myaccount.google.com/permissions . Revoking access through Google will prevent ToniAgent from accessing your calendar data, but you should also disconnect the integration within ToniAgent to delete the locally stored data.

Data Portability:

Your calendar events remain in your Google Calendar at all times. You may export your calendar data directly from Google Calendar using Google Takeout ( takeout.google.com ).

GDPR Rights (EEA Users):

• Right of Access: View all connected Google accounts and synchronised calendar data through your ToniAgent account.
• Right to Erasure: Delete all Google Calendar data by disconnecting your Google account.
• Right to Data Portability: Export your calendar data from Google Calendar directly.
• Right to Restriction: Disconnect individual calendars to stop synchronising specific calendar data.

7. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal or regulatory reasons. We will notify you of any material change by publishing the new policy on this page and updating the "Last updated" date at the top.

8. Contact

If you have questions about this Privacy Policy or about how we handle your data, please contact us at:

Productivity Agents SL Carrer Santa Eulalia 5 08195 Sant Cugat del Vallès, Spain Email: support@toniagent.com · Privacy: privacy@toniagent.com