Terms and Conditions of Service

Last updated: April 24, 2026

Important: These Terms and Conditions constitute a legally binding agreement. Please read them carefully before using our service.

1. Identification of the Service Provider

These Terms and Conditions govern the use and contracting of the platform Wasapia, owned by Disfuse, with registered address at Harju maakond, Tallinn, Tartu, mnt 67, 10115, Estonia, registered in the Estonian Commercial Register, hereinafter referred to as "THE PROVIDER."

Contact email: hello[a]wasapia.com. Modify [a] with @. This is to prevent spam bots.

2. Purpose of the Service

THE PROVIDER offers business users (hereinafter, "THE CLIENT") a platform to create and deploy AI-powered voice conversational agents. The service includes:

  • Inbound and outbound phone call handling via Twilio telephony infrastructure
  • Real-time speech-to-text transcription of voice conversations
  • AI-powered natural language responses using OpenAI GPT models
  • Conversation history storage and management
  • Optional post-call summaries and notifications
  • Integration capabilities with third-party systems via webhooks and HTTP tools

Important: The service processes phone conversations in real-time, transcribing speech, sending transcripts to artificial intelligence systems for processing, and generating natural language responses. Voice recordings are NOT stored – only text transcripts are retained in the platform's database.

2.1 Use of Artificial Intelligence and Third-Party Processors

⚠️ Important Notice: This service relies on third-party AI and telephony providers to function. By using this service, THE CLIENT acknowledges and accepts the following:

OpenAI (Artificial Intelligence Processing)

THE PROVIDER uses OpenAI's GPT models (via OpenAI API) to power conversational voice agents. This means:

  • Call transcripts and messages are transmitted in real-time to OpenAI's API servers
  • Personal data contained in conversations (including names, phone numbers, emails, and any information shared during calls) is processed by OpenAI
  • OpenAI retains API data for 30 days for abuse and misuse monitoring purposes
  • OpenAI is headquartered in the United States; data transfers are subject to US privacy laws
  • Data Processing Agreement: THE PROVIDER does not currently have a formal Data Processing Agreement (DPA) with OpenAI. THE CLIENT acknowledges this and accepts the associated risks
  • OpenAI's API data usage policy applies: https://openai.com/policies/api-data-usage-policies

Twilio (Telephony Infrastructure)

THE PROVIDER uses Twilio's cloud communications platform to handle phone call infrastructure:

  • Twilio receives, routes, and processes all phone calls in real-time
  • Twilio performs speech-to-text transcription of voice audio
  • Twilio processes voice patterns, phone numbers, call duration, and conversation metadata
  • Voice audio is processed in real-time and is NOT stored by Twilio or THE PROVIDER
  • Twilio is headquartered in the United States; data transfers are subject to US privacy laws
  • Data Processing Agreement: THE PROVIDER does not currently have a formal Data Processing Agreement (DPA) with Twilio. THE CLIENT acknowledges this and accepts the associated risks
  • Twilio's privacy policy: https://www.twilio.com/legal/privacy

🔴 Legal Disclaimer – Absence of Formal Data Processing Agreements

THE PROVIDER currently operates without formal Data Processing Agreements (DPAs) with OpenAI and Twilio. While THE PROVIDER implements reasonable security measures, THE CLIENT acknowledges that the absence of formal DPAs may present compliance risks under GDPR Article 28. THE CLIENT accepts full responsibility for assessing whether this service meets their data protection obligations and for obtaining appropriate consent from end-users. THE PROVIDER recommends that THE CLIENT consult with legal counsel before using this service for processing personal data of EU residents.

THE CLIENT's Responsibility: THE CLIENT is responsible for informing their end-users (call recipients/callers) about the use of AI processing and third-party services, and for obtaining any necessary consents as required by applicable data protection laws (GDPR, CCPA, etc.).

3. Acceptance of the Terms

Registration on the platform and use of the service constitute express acceptance of these Terms and Conditions, including the acceptance of Annex I – Data Processing Agreement.

4. Client Obligations

  • Use the service in compliance with applicable laws, particularly data protection and telecommunications regulations.
  • Obtain informed and valid consent from end users when required, and comply with the information duties under Article 13 of the GDPR.
  • Not use the service for unlawful purposes or in a manner contrary to good faith or public order.
  • Indemnify THE PROVIDER against any claims resulting from THE CLIENT's failure to comply with applicable laws.

5. Liability of the Provider

  • THE PROVIDER is not responsible for the content of transcripts nor for the use THE CLIENT makes of them, providing only the technical service.
  • THE PROVIDER does not guarantee uninterrupted availability of the service but will use reasonable efforts to maintain an uptime of 99%.
  • THE PROVIDER shall not be liable for:

a) Temporary service downtime due to maintenance, technical issues, or force majeure.

b) Indirect damages, loss of profit, or loss of business reputation.

In any case, THE PROVIDER's total liability shall not exceed the total amount invoiced to THE CLIENT in the last three (3) months.

6. Intellectual Property

The software, designs, and contents of the platform are the exclusive property of THE PROVIDER. THE CLIENT retains ownership of their data and transcripts. AI models and algorithms used or trained in the provision of the service do not grant any intellectual property rights to THE CLIENT.

7. Term and Termination

  • The contract remains valid as long as THE CLIENT maintains an active account.
  • Either party may terminate the contract at any time by giving 15 days' prior notice.
  • THE PROVIDER may suspend or cancel the service immediately in case of breach by THE CLIENT.
  • Payments already made will not be refunded unless termination is due to a material breach by THE PROVIDER.

8. Pricing, Billing and Refund Policy

  • Service prices are displayed on the website/app and may be modified with at least 15 days' prior notice.
  • Billing will be carried out monthly or annually depending on the chosen plan.
  • Non-payment entitles THE PROVIDER to suspend the service until payment is settled.
  • Refunds will not be issued once the service has been provided, except in cases of error attributable to THE PROVIDER.

9. Incident Resolution and Support Procedure

  • THE CLIENT may report incidents or request support through [support email] or the user dashboard.
  • THE PROVIDER commits to respond within a maximum of 72 business hours.
  • Resolution times are not guaranteed unless specific SLAs are agreed under a separate contract.

10. Right to Modify the Terms

THE PROVIDER may amend these Terms and Conditions by notifying THE CLIENT at least 15 days in advance. Continued use of the service after such notice shall constitute acceptance of the modifications.

11. Governing Law and Jurisdiction

These Terms and Conditions are governed by the laws of Estonia. Any disputes shall be submitted to the Courts and Tribunals of Tallinn (Estonia).

📌 Annex I – Data Processing Agreement (GDPR)

1. Subject Matter

THE PROVIDER shall act as DATA PROCESSOR, processing on behalf of THE CLIENT (DATA CONTROLLER) the personal data derived from phone call transcripts.

2. Purpose

The sole purpose of the processing is to provide transcription, storage, and access to transcripts through the platform.

3. Types of Data

The processed data may include:

  • Phone numbers (caller and recipient)
  • Names, email addresses, and contact information
  • Conversation transcripts (text content of calls)
  • Call metadata: date, time, duration, language settings
  • Voice patterns (processed in real-time by Twilio but not stored)
  • Any other personal information communicated during phone calls and captured in transcripts
  • AI agent configurations and instructions (system prompts)

Note: Voice recordings are NOT stored. Twilio processes voice audio in real-time for transcription purposes only, after which the audio is discarded.

4. Obligations of the Processor (THE PROVIDER)

THE PROVIDER undertakes to:

a) Process data only in accordance with THE CLIENT's documented instructions.

b) Implement appropriate technical and organizational security measures (encryption in transit and at rest, access control, backups).

c) Ensure confidentiality of authorized personnel.

d) Not disclose data to third parties except where required by law.

e) Delete or return all personal data at the end of the service.

f) Assist THE CLIENT in responding to data subject rights requests.

5. Sub-processing

THE CLIENT authorizes THE PROVIDER to engage the following third-party sub-processors for service provision:

  • OpenAI (United States) – AI language model processing
  • Twilio (United States) – Telephony and voice transcription
  • DigitalOcean (United States/Germany) – Cloud hosting and database
  • Stripe (United States/Ireland) – Payment processing
  • MailerSend (EU) – Email delivery
  • BetterStack (EU) – System logging and monitoring
  • Google Analytics (United States) – Website analytics
  • Tidio (Poland) – Customer support chat

⚠️ Important: Many of these sub-processors are located outside the European Union (primarily in the United States).

While THE PROVIDER makes reasonable efforts to ensure data protection, formal Data Processing Agreements (DPAs) are not currently in place with all sub-processors. THE CLIENT acknowledges this limitation and accepts the associated compliance risks. Data transfers to the United States are subject to US privacy laws and may not provide the same level of protection as EU law.

THE PROVIDER will notify THE CLIENT of any changes to the list of sub-processors with at least 15 days' notice.

6. Duration

This Data Processing Agreement remains in force for the duration of the contractual relationship between the parties.

📌 Electronic Acceptance

By accepting the Terms and Conditions during the registration process, THE CLIENT acknowledges having read and accepted both the general Terms and Conditions and this Data Processing Agreement.

Contact Information

If you have questions about these Terms and Conditions, please contact us at: hello[a]wasapia.com

Legal Notice: These Terms and Conditions constitute a legally binding agreement between you and Disfuse. Please read them carefully and consult with legal counsel if you have any questions about your rights and obligations.