1 · PRIVACY POLICY
Last updated: 21 July 2026
At Ayomi we do something simple: we call older people each day so they don't spend the day in silence. To do that we process personal data, and we want to explain clearly which data, what for, and what you can do about it. No small print hiding what matters.
1.1 · Who is responsible for your data
The data controller is:
- Cuandeoro Limited, a company registered in Ireland.
- Company registration number (CRO): 813028.
- Registered office: Dublin, D16 PF54, Ireland.
- Contact for privacy matters: legal@ayomi.ie
If at any point you have a question about how we handle your data, or you wish to exercise any of your rights, write to that address. We will reply.
1.2 · Who the service is for
Ayomi is a companionship service, not a health service. It is usually taken out and paid for by the adult son or daughter of an older person. There are, therefore, two people whose data may be processed:
- The person who signs up (usually the son or daughter): who creates the account, pays the subscription and provides the contact details.
- The older person who receives the calls: they are the recipient of the service and, in data-protection terms, a data subject with rights of their own. Before they begin receiving calls they are informed, and their verbal consent is obtained at the start of the first call.
Ayomi is not a telecare, emergency or health-monitoring service. We do not watch over anyone, we do not measure medical parameters, we do not give clinical alerts. We keep company.
1.3 · What data we process and why
We distinguish between what we process today (website and contact form) and what we will process when the calling service is active, so you know exactly where things stand.
A) Today — visiting the site and the contact form
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Name, email, phone and message you enter in the contact form | To reply to your enquiry and get in touch | Consent (art. 6(1)(a)) and/or pre-contractual steps at your request (art. 6(1)(b)) |
| IP address and basic technical connection data | To serve the page and its fonts; basic site security | Legitimate interest in providing and protecting the site (art. 6(1)(f)) |
The form data is sent to us by email through our email provider (see §1.5). We use no analytics, no tracking cookies and no advertising tools on the site. The only marker we store in your browser is technical and serves to remember that you have accepted the cookie notice (see the Cookie Policy).
B) When the calling service is active
When you take out the service, to provide it we will also process:
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| The older person's phone number and preferred call time | To make the daily companionship call | Performance of the contract (art. 6(1)(b)) and consent (art. 6(1)(a)) |
| Recording and/or transcript of the older person's calls | To generate a short summary for the family and give continuity to the conversation (to recall what was discussed) | Consent (art. 6(1)(a)) |
| Contact details of the person who signs up and billing data | To manage the account, collect the subscription and communicate with the family | Performance of the contract (art. 6(1)(b)) and legal obligations, e.g. accounting (art. 6(1)(c)) |
| Family plan only: recording of the caller's voice to clone it and use it in the opening greeting | So the older person receives a greeting in their relative's voice before Ayomi continues | Explicit consent for biometric data (art. 9(2)(a)) |
Important regarding the cloned voice (Family plan): a relative's voice is biometric data, a specially protected category. Its processing therefore requires explicit, separate consent, collected with its own tick-box at the moment of activation — never hidden inside the general terms. The cloned voice is used only for the opening greeting; the rest of the conversation is always carried by Ayomi's own voice. You may withdraw this consent at any time (see §1.7).
The AI always identifies itself as AI. On every call, Ayomi makes clear — warmly, not as small print — that it is an artificial-intelligence companion and not a person. This is a commitment of ours and, moreover, a legal obligation (EU AI Act, art. 50).
Nothing medical. We do not ask about symptoms, we do not record health data, we do not produce diagnoses or clinical reports. If, in everyday conversation, the older person mentions they slept well or what they had for lunch, it is treated as casual chat, not as medical information.
1.4 · Where the data comes from
- The form data is provided by you directly.
- The older person's data (phone number, call time) is usually provided by the person who signs up. In that case, the person who signs up confirms they are entitled to provide it and undertakes to inform the older person. In any event, the older person is informed and gives verbal consent at the start of the first call before the service continues.
1.5 · Who we share data with (processors)
To provide the service we rely on technology providers acting as processors, that is, they process data on our behalf and under contract (data processing agreement, DPA). Some are located outside the European Economic Area, mainly in the United States; in those cases, the international transfer is covered by the Standard Contractual Clauses (SCCs) approved by the European Commission or another valid GDPR mechanism.
| Provider | Purpose | International transfer |
|---|---|---|
| Brevo (Sendinblue) | Sending the contact-form email and email communications | May involve processing outside the EEA — covered by SCCs |
| Twilio | Telephony: making the calls | US — SCCs |
| ElevenLabs | Synthetic voice and, on the Family plan, cloning the relative's voice | US — SCCs |
| Google / Gemini | The AI that sustains the conversation; the site also loads Google Fonts (see §1.6 and the Cookie Policy) | US — SCCs |
We do not sell your data. We do not share it with third parties for advertising. We only share it with these processors, for what is strictly necessary, and with public authorities where a legal obligation requires it.
1.6 · Google Fonts
Our site uses Google Fonts. To display them, your browser connects to Google's servers, which means your IP address is transmitted to Google (US). This is common on the modern web, but we prefer to tell you plainly. We rely on our legitimate interest in presenting the site legibly and with care.
1.7 · How long we keep the data
We keep data only for as long as necessary for the purpose it was collected for. These periods are a reasonable proposal, pending legal validation:
| Data | Proposed period |
|---|---|
| Contact-form messages | Up to 12 months from the last contact, unless the enquiry leads to a contractual relationship |
| Customer account and contact data | While the subscription is active and up to 12 months after cancellation |
| Billing data | The period required by Irish accounting and tax rules (usually 6 years) |
| Call recordings/transcripts | The minimum necessary to generate the summary. Proposal: keep the recording only until the summary is generated and then keep only the summary for 90 days; the raw recording is deleted |
| Relative's cloned voice (Family plan) | While the Family plan is active and consent is not withdrawn; deleted on cancellation or withdrawal of consent |
When we no longer need the data, we delete or securely anonymise it.
1.8 · Your rights
As a data subject, you have the right to:
- Access your data and know how we process it.
- Rectify inaccurate data.
- Erase your data ("right to be forgotten") where applicable.
- Object to certain processing.
- Request the restriction of processing.
- The portability of your data to another controller.
- Withdraw your consent at any time (for example, the cloned-voice consent), without affecting the lawfulness of processing before withdrawal.
To exercise any of these rights, write to legal@ayomi.ie. It is free and we will reply within the periods set by law. We may ask you to prove your identity to protect your data.
1.9 · Complaints to the supervisory authorities
If you believe we have not handled your data properly, you may complain to the competent supervisory authority:
- Ireland — Data Protection Commission (DPC): www.dataprotection.ie
- Spain — Agencia Española de Protección de Datos (AEPD): www.aepd.es
We would be grateful if, before complaining, you wrote to legal@ayomi.ie: almost everything is resolved by talking.
1.10 · Older and vulnerable people
Ayomi is intended for older people, who in data-protection terms may be considered a particularly vulnerable group. Therefore:
- We design the service with special care for their dignity and their understanding of what is happening.
- The older person always knows they are speaking to an AI.
- We obtain their consent clearly and verbally at the start, and we always respect their wish to stop receiving calls ("don't call me again" is always honoured).
- We minimise the data we process and we do not process health data.
1.11 · Automated decisions
The conversation is generated by an artificial-intelligence system, but we make no automated decisions with legal or similarly significant effects on people (we do not assess, score or clinically classify anyone). Ayomi converses and keeps company; it does not decide about anyone's life.
1.12 · Minors
The service is aimed at adults. It is not intended for minors, and we do not knowingly collect minors' data.
1.13 · Impact assessment (DPIA)
As we process data of a vulnerable group, we are carrying out the corresponding Data Protection Impact Assessment (DPIA) before the calling service goes live.
1.14 · Changes to this policy
We may update this policy. Where a change is significant, we will communicate it by appropriate means. The date of the last update appears at the top.