Legal

Privacy Policy

What personal data we process, why we process it, how long we keep it, and the rights you have over it.

Last updated: 16 July 2026

1. Who is responsible for your data

GHL Spark, of 371/3 Sonadanga RA, Khulna, Bangladesh, operates GHL Spark AI. For privacy questions contact ghlsparkai@gmail.com or call +8801303519535.

An important distinction. For our own customers (agencies and businesses who buy Spark AI) we are the controller of that account data. For the people who call our customers — their callers and leads — we act as a processoron our customer's behalf: they decide why that call happens and what is done with it. If you are a caller and want your data removed, contact the business you called; we will support them in doing so. See the Data Processing Addendum.

2. What we collect

From our customers

  • Account details: name, business name, email, phone number.
  • Billing details. Card data is handled by our payment processor — we do not store full card numbers.
  • Configuration: your agent scripts, business hours, routing rules and calendar settings.
  • Usage and diagnostic data: logins, feature usage, error logs.

From callers, on behalf of our customers — this is the sensitive part

  • Call audio recordings and their AI-generated transcripts.
  • Caller phone number, name, and anything the caller says during the call — which may include an address, a job description, availability, or financial information such as investable assets, depending on which agent is configured.
  • Outcomes derived by the AI: lead score, intent classification, booking made.
  • SMS message content sent and received.

Callers may volunteer information we never asked for, including special-category data (for example health information, when describing an emergency). Our customers should configure scripts so as not to solicit it, and should not use it for anything beyond servicing the call.

3. Data we access in your GoHighLevel account

Spark AI installs into your GoHighLevel (“GHL”) account as a Marketplace app and connects through GoHighLevel's OAuth. With your authorisation, and only for the agents you enable, it requests the minimum sub-account scopes it needs to run Voice AI on your behalf:

  • voice-ai-dashboard.readonly (Read) — view voice AI call logs and call details.
  • voice-ai-agents.readonly (Read) — view voice AI agents and available voices.
  • voice-ai-agents.write (Write) — create, update and delete voice AI agents.
  • voice-ai-agent-goals.readonly (Read) — view voice AI agent goals and actions.
  • voice-ai-agent-goals.write (Write) — create, update and delete voice AI agent goals and actions.

The exact set of scopes is always shown on the GoHighLevel consent screen before you approve the installation, and that screen is the authoritative record of what you have granted. We request nothing beyond what the agents you enable actually need.

We access your GoHighLevel data only to provide the service to you. We do not sell it, we do not use it for advertising, and we do not use it to train AI models except as described in “Do we train AI models on your data?” below.

Uninstalling and deletion. When you uninstall the app from the GoHighLevel Marketplace, cancel your subscription, or disconnect the integration, our access token is revoked and we stop accessing your account. We delete or return the GoHighLevel data we hold within 14 days, and you can ask us to delete it sooner by contacting ghlsparkai@gmail.com. Your GoHighLevel account is also governed by GoHighLevel's own privacy policy.

4. Why we process it, and on what legal basis

  • To provide the service — performance of our contract with you.
  • To bill you — contract and legal obligation.
  • To keep the service secure and debug it — our legitimate interest in a working, non-abused product.
  • To handle calls on our customers' behalf — on their documented instructions, under their legal basis. It is their responsibility to establish that basis and to obtain caller consent to recording where the law requires it.
  • Marketing to you — consent, or legitimate interest where permitted. You can opt out at any time.

5. Do we train AI models on your data?

No.We do not use your account data, your callers' personal data, call recordings, transcripts, or the GoHighLevel data we access to train or fine-tune our own AI models.

We send call audio and text to our AI and speech providers only to process an individual call and return the result to you. Under our agreements with those providers, they process this data solely to provide that service and do not use it to train their own models. If we ever propose to change this, we will update this policy and give you the choice to opt out before the change takes effect.

6. Who we share it with

We share data with the sub-processors needed to run the service — hosting, telephony, AI model providers, CRM (GoHighLevel), payments and email. They are listed, with their purpose and location, in the Data Processing Addendum. We do not sell personal data.

7. International transfers

Some sub-processors are outside your country, including in the United States and the European Union. Where personal data is transferred across borders, we rely on the data protection laws of the country in which each sub-processor operates, together with the contractual commitments in our agreements with them and encryption in transit and at rest.

8. How long we keep it

  • Call recordings and transcripts: kept for the life of your subscription and deleted within 14 days of cancellation — configurable per customer.
  • Account and billing records: kept while you are a customer and deleted within 14 days, except where we must keep them longer to meet a legal, tax or accounting obligation.
  • Diagnostic logs: up to 14 days.
  • GoHighLevel data accessed via the app: deleted or returned within 14 days of uninstalling or cancelling.

9. Security

We use encryption in transit and at rest, access controls, and least-privilege access to production systems. No system is perfectly secure; if a breach affects your data we will notify you and, where required, the relevant regulator, without undue delay.

10. Your rights

Depending on where you live, you may have the right to access, correct, delete, port or restrict your data, to object to processing, and to withdraw consent. To exercise them, contact ghlsparkai@gmail.com. As Spark AI is distributed through the GoHighLevel Marketplace, you can also raise concerns about the app through the GoHighLevel Marketplace, and, where one exists, with the data protection authority in your country of residence.

If you are in California, you may have additional rights under the CCPA/CPRA, including the right to know what is collected and to opt out of “sharing”. We do not sell personal information.

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12. Changes

We will post updates here and change the “last updated” date. Material changes will be notified directly.