Cole

Privacy Policy

Last updated: September 9, 2026

This is a template starting point, not legal advice. It has not been reviewed by a lawyer. Given the sensitive personal data some campaigns handle, get this reviewed by counsel — and fill in your actual company legal name, refund policy, and governing-law jurisdiction — before relying on it.

1. Overview

This Privacy Policy explains how Cole ("Cole," "we," "us"), operated by GetCole Innovation Inc, collects, uses, and shares personal data. It covers two distinct groups: (a) Customers who sign up to use Cole, and (b) Leads — the people a Customer's campaign contacts on their behalf. If you're a Lead who received an outreach email or call and want your data removed, see Section 7.

2. Data we collect about Customers

  • Account information: name, email, and authentication data (via Clerk)
  • Billing information: processed directly by Stripe — Cole does not store your card number
  • Campaign configuration: your ICP description, outreach templates, calendar and CRM connection settings
  • Usage data: campaigns created, credits consumed, actions taken in the dashboard

3. Data we collect about Leads

When a Customer runs a campaign, Cole processes data about the people that campaign targets, on the Customer's behalf and under their direction. This may include:

  • Name, email address, phone number, and company/role information
  • Outreach and reply history (email content, classification of replies)
  • Voice call recordings and transcripts, where a qualification or reminder call takes place
  • Meeting scheduling data (booked times, confirmations, no-shows)
  • For partnership/community outreach, information about organizations contacted for co-marketing

Cole acts as a data processor for this Lead data — the Customer directing the campaign is the data controller responsible for having a lawful basis to contact each Lead.

4. Sensitive data — please read if this applies to your use case

Some campaigns (for example, outreach aimed at family members monitoring the wellbeing of elderly relatives) may involve discussion of health, wellbeing, or family-care topics during outreach or voice calls. This is a sensitive data category under most privacy laws (including GDPR and India's DPDP Act) and requires extra care — explicit consent mechanisms, data minimization, and potentially a Data Protection Impact Assessment, depending on your jurisdiction and use case. If your campaign involves this kind of data, get specific legal advice before launch — this template does not constitute that advice.

5. How we use data

We use Customer data to operate and bill for the service, and we use Lead data exclusively to execute the outreach, qualification, and booking pipeline the Customer configured — sourcing, messaging, voice qualification, scheduling, and follow-up. We do not sell personal data, and we do not use Lead data for any purpose beyond running the Customer's campaign.

6. Who we share data with

The following third parties process data on our behalf to operate Cole:

  • Stripe — payment processing
  • Clerk — authentication and account management
  • Vapi — AI voice call infrastructure
  • Cal.com — meeting scheduling
  • Resend — outbound email delivery
  • Anthropic — AI models used for ICP translation, lead discovery, and conversation
  • Apollo / Clay — B2B lead sourcing and enrichment
  • A Customer's own connected CRM (HubSpot or HighLevel), only if the Customer enables that sync
  • Infrastructure providers (Vercel, Supabase, Railway, Upstash) hosting the application and database

7. Data retention and deletion

We retain Customer and Lead data for as long as the associated account or campaign is active, plus a reasonable period for audit and legal-compliance purposes. Every status change in the pipeline is recorded in an append-only audit log. To request deletion of your data — whether you're a Customer or a Lead who wants to opt out — contact us at hi@getcole.app.

8. Your rights

Depending on your location, you may have rights to access, correct, delete, or export your personal data, and to object to or restrict certain processing. Contact us at hi@getcole.app to exercise these rights.

9. Security

We use industry-standard measures to protect data in transit and at rest, including encrypted connections and access controls. No system is completely secure, and we cannot guarantee absolute security.

10. International transfers

Data may be processed in countries other than where you or your Leads are located. Where required, we rely on appropriate safeguards for such transfers.

11. Changes to this policy

We may update this Privacy Policy from time to time. We'll update the date at the top of this page when we do.

12. Contact

Questions about this Privacy Policy? Contact us at hi@getcole.app.