AI phone agents · Last updated: 26 October 2026

A GDPR-conscious AI phone agent, with the paperwork published

Digiflowhub builds AI phone agents that answer calls, take bookings and requests, and hand over to a person when needed. Instead of vague hosting promises, we publish the paperwork: the full AVV, every sub-processor with its location and transfer basis, AI disclosure at the start of every call, and retention you control.

What the voice agent does

A GDPR checklist for any AI voice agent

The longer version: is AI automation GDPR compliant?

Sub-processors, in English

This is an English summary of Anlage 2 of our AVV. The services used for your project are marked in your own AVV; not every project uses all of them.

ServicePurposeWhere data is processedTransfer basis
Vapi (Vapi Inc.)Runs the phone agent: call handling, conversation flow, recording, transcriptUSAStandard contractual clauses (Vapi DPA)
ElevenLabs (Eleven Labs Inc.)Voice output (text to speech)USA, EU data residency depending on contractEU-US Data Privacy Framework and standard contractual clauses
Twilio (Twilio Inc. / Twilio Ireland Ltd.)Phone number, call forwarding, SMSUSA, EUEU-US Data Privacy Framework and standard contractual clauses
OpenAI (OpenAI Ireland Ltd.)Language model for the conversationUSAStandard contractual clauses (OpenAI DPA)
Anthropic (Anthropic PBC)Language model for texts, summaries, assistantsUSAStandard contractual clauses (Anthropic DPA)
Transcription (Deepgram or Gladia, per project)Speech to textUSA or EU, depending on the providerStandard contractual clauses where needed
Supabase (Supabase Inc.)Database for bookings, orders and call logsEU (Frankfurt region)Standard contractual clauses for support and operations from the USA
Vercel (Vercel Inc.)Hosting of web pages, dashboards and interfacesEU and USAEU-US Data Privacy Framework and standard contractual clauses
Make (Celonis s.r.o.)Automations such as notifications and calendar entriesEUNot needed
Google Workspace (Google Cloud EMEA Ltd.)Email, calendar, documentsEU and USAEU-US Data Privacy Framework and standard contractual clauses

Digiflowhub runs no servers of its own. Language models are used through business API access, whose inputs the providers say are not used for training.

Caller notice and AI disclosure

Every call starts with the agent saying that it is an AI (EU AI Act, Art. 50). Your privacy notice for callers explains the recording and processing. Staff who work with the system get a short introduction, as the AI Act expects (Art. 4).

Retention and deletion

Retention is set per project in the AVV. The default in our template is 30 days for recordings and transcripts and 90 days for reservation and order data, then deletion unless you instruct otherwise. When the contract ends, all personal data is deleted or returned within 30 days at the latest.

Pricing

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Frequently asked questions

Is an AI phone agent GDPR compliant in Germany?

It can be, when there is a data processing agreement (AVV) under Art. 28 GDPR, a documented list of sub-processors and transfer bases, limited retention, a privacy notice for callers, and AI disclosure at the start of each call. Digiflowhub provides all of these and publishes the AVV template. Whether your setup is compliant also depends on how you use it, so we recommend a quick review with your data protection officer or lawyer.

Where is call data processed?

In the EU where possible. The database for bookings, orders and call logs runs in the EU (Frankfurt region), and Make runs in the EU. Some services, such as the call platform Vapi and the language models from OpenAI and Anthropic, process data in the USA under standard contractual clauses or the EU-US Data Privacy Framework. Voice output (ElevenLabs) and telephony (Twilio) run in the USA or the EU depending on the contract. The services used for your project are marked in your AVV.

Do callers have to be told they are talking to an AI?

Yes. Under Art. 50 of the EU AI Act, people must be told when they interact with an AI system. Our phone agents say so at the start of every call.

Do you sign an AVV / DPA?

Yes. Every client gets a data processing agreement under Art. 28 GDPR. The template is published in German at digiflowhub.com/avv.

How long are call recordings kept?

You decide. The default in our AVV template is 30 days for recordings and transcripts and 90 days for reservation and order data, after which they are deleted unless you instruct otherwise.