If you received a call or text message from Syntharra about an outstanding invoice, this notice is for you. Syntharra Limited (“Syntharra”, “we”, “us”) is an Irish-incorporated company that places AI-assisted voice calls and SMS messages on behalf of businesses to follow up on their unpaid invoices. This notice tells you what personal data we hold about you, why we hold it, your rights, and how to contact us.
This notice satisfies our obligations under Article 14 of the EU General Data Protection Regulation and the equivalent provisions of the UK GDPR. If you are in the United States, additional rights are described in Section 9 below.
1. Who we are
Syntharra Limited is a company incorporated in Ireland (registered address: pending publication after CRO registration). For data-protection purposes, we are the controller (jointly with the client business who instructed us to contact you) of the personal data described in this notice. Our lead supervisory authority is the Data Protection Commission of Ireland (dataprotection.ie).
2. Why you received our call or message
A business that has issued you an unpaid invoice has engaged Syntharra to follow up on that invoice on its behalf. The business gave us your phone number from its accounting system, having received it from you originally for business communication. We do not purchase, buy, or own your debt. The original business remains the creditor; we act only as a service provider to that business.
3. What personal data we hold about you
- Your name (as recorded in the client business’s accounting system).
- Your phone number.
- Where provided by the client business: your email address and postal address.
- Invoice information relating to your account with the client business: invoice number, amount, date, due date, and payment status.
- Recordings and transcripts of any call we placed to you, or any SMS exchange.
- If you opt out: a record of your opt-out, including the date and method.
4. Why we process your data (legal basis under GDPR Article 6(1)(f))
We process your personal data on the basis of the legitimate interest of the original business in recovering amounts you owe under your existing commercial relationship with that business. We have carried out a documented balancing test which considers your rights as a data subject, the limited and transactional nature of the contact, the frequency caps applied (maximum 3 attempts per invoice, minimum 3 days between attempts, 9am-8pm in your local time, weekdays only), and your right to object at any time. A summary of the assessment is available on request.
We do not use your data for marketing, profiling, automated decision-making with legal or similarly significant effects, or any purpose other than follow-up on the specific invoice you owe to the client business that engaged us.
5. Call recording and AI identification
Calls we place to you are recorded for the purposes of quality, dispute resolution, training, and statutory compliance. The recording disclosure is given at the start of every call. The caller is an AI assistant, not a human; this is also disclosed at the start of every call.
If you do not want the call to be recorded, you may say so at the start of the call and we will end the call. We treat your voice recording as sensitive personal data and do not use it for any purpose beyond providing the service to the client business and the de-identified service-improvement use described in our main Privacy Policy.
6. How long we keep your data
- Your contact information: deleted within 30 days of the invoice being marked paid or archived by the original business, or 30 days of that business closing its Syntharra account.
- Call recordings and transcripts (US numbers): up to 4 years from the call date, for the purpose of defending statutory claims.
- Call recordings and transcripts (EEA, UK, or other non-US numbers): up to 24 months from the call date.
- Your opt-out record: indefinitely, in order to honour your opt-out. This record contains only your phone number and the fact and date of opt-out; we remove it only on documented written request to legal@syntharra.com.
7. Your rights
You have the following rights, exercisable free of charge:
- To stop receiving calls or texts (right to object). Say “stop”, “do not call me”, “remove me”, or “DNC” during a call; reply “STOP” to any SMS; or use the self-serve form at /unsubscribe. Opt-out is instant and global across all clients of the platform.
- Access — request a copy of the personal data we hold about you.
- Rectification — ask us to correct inaccurate data.
- Erasure — ask us to delete your data, subject to the retention periods above where they are required for legal-defence purposes.
- Restriction and object — ask us to restrict processing or object to it. We will act on your objection immediately for processing based on legitimate interests, unless we can demonstrate compelling legitimate grounds that override your interests.
- Portability — receive your data in a structured, machine-readable format.
- Complain — you have the right to lodge a complaint with a supervisory authority. In Ireland, the Data Protection Commission (dataprotection.ie); in the UK, the ICO (ico.org.uk).
To exercise any of these rights, email legal@syntharra.com. We respond within one month and may extend by up to two further months for complex requests, giving you reasons.
8. Who we share your data with
We share your data only with the service providers needed to operate the call, message, and any payment you choose to make through a link we send you. The current list is maintained at /legal/subprocessors. We do not sell your data. We do not use your data for advertising. We do not share your data with the original business’s competitors, with credit-reference agencies, or with any third party for purposes other than supporting the service.
9. US recipients (state privacy laws)
If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Florida, Tennessee, New Hampshire, New Jersey, or another US state with a comprehensive consumer-privacy law, you have additional rights including the right to know what information we hold about you, the right to correct, the right to delete (subject to the legal-retention exceptions above), the right to opt out of any sale or sharing of personal information (we do not sell or share), and the right to limit the use of sensitive personal information (we treat your voice recording as sensitive and limit its use accordingly). To exercise any of these rights, email legal@syntharra.com.
10. UK recipients
If you are in the United Kingdom, the appointment status of our UK Article 27 representative is shown at /legal/subprocessors. You may contact the representative (where appointed) or contact us directly at legal@syntharra.com.
11. Contact
Data-protection inquiries: legal@syntharra.com.
Self-serve opt-out: email legal@syntharra.com, or visit /unsubscribe where deployed.
Lead supervisory authority: Data Protection Commission of Ireland, dataprotection.ie.