Privacy Policy

Last updated

This Privacy Policy explains how Cal.com, Inc. ("Cal.com", "we", "us") handles personal data in connection with COSS: the website and documentation at coss.com, the dashboard, the API and the SDK (together, the "Services"). Capitalized terms not defined here have the meaning given in our Terms of Service.

The short version

  • We collect what we need to run COSS: your account details, the data your organization sends through the API, and the technical data needed to keep the Services secure.
  • For the messages you send through COSS, you decide what is sent and to whom. We process that data on your behalf, as your processor.
  • We automatically screen a sample of live messages for spam, phishing, malware and fraud, including with AI models. The AI provider retains nothing.
  • We don't sell or share personal data for advertising, and coss.com runs no third-party analytics or advertising scripts.
  • Cal.com participates in the EU-U.S. Data Privacy Framework and its UK Extension.
  • Questions? Write to privacy@cal.com.

1. Who's who: controller and processor

Cal.com as controller. We decide how and why personal data is processed, and are responsible for it as controller (or "business" under California law), for:

  • your account and the members of your organization;
  • billing and the business relationship with you;
  • security, abuse prevention and the reputation of the Services;
  • visits to coss.com and our communications with you.

Cal.com as processor. When you use the API or dashboard to send messages, the personal data in them is Customer Data: message content, attachments, recipient addresses, delivery events, suppression lists and the like. Your organization is the controller of Customer Data, and we process it only on its instructions, under the Terms and our Data Processing Addendum (DPA). If you received a message sent through COSS and want to exercise your privacy rights, please contact the sender: they control that data. If you contact us instead, we will forward your request to them where we can, and help them respond.

2. What we collect

Account and organization data. Name, email address, password (stored only as a salted hash), two-factor authentication settings and backup codes, passkey public keys, and, if your organization uses single sign-on, the identity your identity provider returns. We also store organizations, projects, environments, memberships, roles and invitations. If you subscribe to a paid plan, we store billing contact details; payment card details are handled by our payment processor and never stored by us.

Sessions and security data. For each sign-in session, we store the IP address and browser user agent, so that you can review and revoke your sessions. We use IP addresses and hashed email addresses to rate-limit sign-in attempts and API requests. Platform administrators' actions are recorded in an audit log.

API keys. API keys are stored only as hashes, together with their environment, permissions and when they were last used.

Customer Data (processed on your behalf).

  • Messages: sender, recipients (to, cc, bcc), reply-to, subject, HTML and text content, headers, tags, category and scheduling details. Attachment contents are stored only until the message is sent, canceled or fails; after that we keep only the attachment's name, type and size.
  • Delivery events: whether each recipient's message was delivered, bounced, complained about, suppressed or failed, with details from the receiving mail server.
  • Open and click tracking: only when you turn it on. When a recipient opens a tracked message or clicks a tracked link, we record the time, the link and the user agent of the request. We do not store their IP address.
  • Suppression lists: addresses not to send to, added after permanent bounces or complaints, or by you.
  • Domains and webhooks: the sending domains you verify and their DNS records; your webhook endpoint URLs and signing secrets (encrypted at rest), and a record of each delivery attempt, including up to 1 KB of your endpoint's response.

Website and documentation. coss.com loads no third-party analytics, advertising or tracking scripts. Our servers and content delivery network process technical data such as IP addresses, request URLs and user agents to serve and protect the site, and keep it in short-lived logs.

Communications. If you contact us, we keep your message and our reply. We send service emails, such as verification, security, and reputation warnings and suspension notices to organization owners and administrators. These are part of the Services and you can't opt out of them while you have an account.

If you are in the European Economic Area (EEA), the UK or Switzerland, we rely on these legal bases under Article 6 of the GDPR (and its UK and Swiss equivalents):

PurposeLegal basis
Creating your account and providing the ServicesPerformance of a contract
Billing and collecting amounts owedPerformance of a contract; legitimate interests
Security, fraud and abuse prevention, rate limiting and content screeningLegitimate interests in protecting the Services, our customers and the people who receive messages
Reputation monitoring and suspensionsLegitimate interests; performance of a contract
Improving the Services with aggregated usage dataLegitimate interests
Service and security emailsPerformance of a contract; legitimate interests
Product news and marketing emailsConsent, where required (you can withdraw it at any time)
Complying with the law and responding to lawful requestsLegal obligation

Where we process Customer Data as a processor, the controller (our customer) is responsible for having a legal basis.

4. Automated content screening

To protect the people who receive messages, and the deliverability of every customer, we automatically screen a sample of messages sent from live environments before delivery. Sandbox messages are never screened.

  • What is screened: a sample of messages per organization, more frequently for new senders. We never tell customers which messages will be sampled.
  • What the model sees: the sender address, the subject, up to 8,000 characters of the message's readable text, and the host and path of its links (query strings removed). It does not see recipient addresses or attachments.
  • Who processes it: the classification runs through Vercel's AI Gateway on AI models from its providers, with zero data retention: they may not keep the content or use it to train models.
  • What we keep: the verdict and its scores, never the message content.
  • What can happen: a message judged highly likely to be spam, phishing, malware or fraud is not delivered and its organization's live sending is suspended. Lower-confidence results can trigger a review of the organization's sending reputation.

A suspension never lifts by itself: a member of our staff reviews it. If you believe a decision is wrong, write to legal@cal.com to have a person review it and to explain your point of view.

5. Who we share it with

We share personal data only as described here:

  • Subprocessors that help us run the Services, under contracts that limit their use of the data to providing their services to us:

    • Amazon Web Services, Inc. (United States): hosting, databases, caching, queues and email delivery (Amazon SES).
    • Vercel, Inc. (United States) and the model providers available through its AI Gateway: AI content screening, with zero data retention.
    • Cloudflare, Inc. (United States): DNS for coss.com.

    The complete, current list of Cal.com subprocessors is in our Trust Center at trust.cal.com. We give customers 30 days' notice of new subprocessors of Customer Data, and they may object on reasonable data protection grounds, as described in the DPA.

  • Message delivery. Sending a message necessarily discloses its content to the recipients' mail servers.

  • Your webhook endpoints receive event data about your messages (never message bodies, headers, cc or bcc).

  • Your organization. Organization owners and administrators can see the members of the organization and the data in it.

  • Legal and safety. We may disclose data if we believe in good faith that the law requires it, or to protect the rights, property or safety of Cal.com, our customers or others, including responding to abuse reports. Where permitted, we will tell the affected customer before disclosing Customer Data.

  • Business transfers. If Cal.com is involved in a merger, acquisition or sale of assets, personal data may be transferred as part of it, subject to this policy.

We do not sell personal data, and we do not share it for cross-context behavioral advertising.

6. How long we keep it

  • Account and organization data: while your account is active. You can ask us to close your account at support@cal.com. After it is closed, you have at least 30 days to export your data, and we then delete it on our standard schedule, except what we must keep by law.
  • Messages and delivery events: while your organization's account is active, so that you can look them up in the dashboard and the API. Your organization can ask us to delete them sooner by writing to privacy@cal.com. Attachment contents are deleted automatically once a message is sent, canceled or fails.
  • Suppression lists, domains and webhook endpoints: until your organization removes them, or its account is closed.
  • Sessions: until they expire or are revoked.
  • Content screening verdicts and reputation history: for as long as the organization exists, so that past decisions can be reviewed.
  • Invoices and tax records: as long as tax law requires, typically 7 to 10 years.
  • Logs: short-lived, then deleted. Backups roll over on a fixed schedule.

7. Where your data goes (international transfers)

We are based in the United States, and process personal data mainly in the United States. When we transfer personal data from the EEA, the UK or Switzerland, we rely on the EU-U.S. Data Privacy Framework and its UK Extension (see section 8). Where appropriate, including for transfers from Switzerland, we use the European Commission's Standard Contractual Clauses and their UK and Swiss equivalents.

8. EU-U.S. Data Privacy Framework and UK Extension

Cal.com, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Cal.com, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (the "DPF Principles") with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension. If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles govern. To learn more about the Data Privacy Framework program, and to view our certification, visit dataprivacyframework.gov.

Our commitment does not cover human resources data transferred for use in an employment relationship.

Inquiries and complaints. In compliance with the DPF Principles, Cal.com commits to resolve DPF Principles-related complaints about our collection and use of your personal data. EU and UK individuals with inquiries or complaints about our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension should first contact Cal.com, Inc., Privacy & Compliance, at privacy@cal.com, or our compliance lead, Felix Kolodziej, at felix@cal.com or +1 415 212 6667. We will respond to DPF complaints within 45 days.

Independent recourse. Cal.com commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner's Office (ICO) and the Gibraltar Regulatory Authority (GRA) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension. These independent recourse mechanisms are available to individuals free of charge. Under certain conditions, described on the DPF website, you may invoke binding arbitration for complaints not resolved by other means.

Enforcement. Cal.com, Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Onward transfers. Cal.com remains responsible for personal data we receive under the DPF and subsequently transfer to third parties acting as agents on our behalf. We remain liable under the DPF Principles if our agents process such personal data in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.

Disclosures to authorities. We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

9. Cookies

The coss.com dashboard uses only cookies that are strictly necessary: to keep you signed in, to complete two-factor authentication and single sign-on, and to protect against attacks. The marketing site and documentation set no cookies of their own, other than these when you are signed in, and we use no third-party advertising or analytics cookies. The site may store display preferences, such as light or dark mode, in your browser's local storage. Because we use no cookies that need consent, there is no cookie banner. We honor Global Privacy Control signals; since we neither sell nor share personal data, there is nothing further for them to switch off.

10. Your rights

Depending on where you live, you may have the right to:

  • access the personal data we hold about you and receive a copy of it;
  • correct inaccurate data;
  • delete your data;
  • object to, or restrict, our processing of it, including processing based on legitimate interests;
  • receive your data in a portable format;
  • withdraw consent at any time, where we rely on consent; and
  • not be subject to a decision based solely on automated processing that significantly affects you, and to obtain human review of such a decision.

Some of these you can exercise yourself in the dashboard: you can update your name and review and revoke your sessions, and your organization can manage its suppression list, domains and webhook endpoints. For anything else, write to privacy@cal.com. We may need to verify your identity before acting on a request, and will respond within the time the law requires (generally one month in the EEA and UK, 45 days in California). We will not discriminate against you for exercising your rights.

EEA, UK and Switzerland. You have the right to lodge a complaint with your local data protection authority. We'd appreciate the chance to address your concern first.

California. California residents have the right to know what personal information we collect, use and disclose; to delete and correct it; and to opt out of its sale or sharing (we do neither), and to limit the use of sensitive personal information (we use it only as permitted for providing the Services and security). In the last 12 months we have collected the categories described in section 2: identifiers, customer records, commercial information, internet or network activity, and account credentials, for the purposes in section 3, and disclosed them only to the recipients in section 5. You may use an authorized agent to make a request on your behalf.

11. Security

We protect personal data with technical and organizational measures appropriate to the risk, including encryption in transit and at rest, encryption of webhook signing secrets with AES-256-GCM, hashed passwords and API keys, least-privilege access for our staff, audit logging of administrative actions, and support for two-factor authentication, passkeys and single sign-on. No system is perfectly secure. If you discover a vulnerability, please report it as described at cal.com/security.

12. Children

The Services are for businesses and are not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, contact us and we will delete it.

13. Changes to this policy

We may update this Privacy Policy from time to time. We will post the new version here and update the "Last updated" date. If the changes are material, we will tell you by email or in the dashboard before they take effect.

14. Contact

Cal.com, Inc.
Privacy & Compliance
2261 Market Street #4382
San Francisco, CA 94114
United States