About Our AI System
This page transparently explains what the Vocalyy voice agent is, how it works, and what limitations it has. We publish this information per the EU Regulation on Artificial Intelligence (EU AI Act, Regulation (EU) 2024/1689) — Article 50(1), which requires providers of AI systems intended for direct interaction with natural persons to ensure that those persons are informed that they are interacting with an artificial intelligence system, unless this is obvious from the context.
1. What is Vocalyy?
Vocalyy is a SaaS platform that provides AI voice agents — conversational systems that answer phone calls on behalf of a business. The agent:
- Answers calls 24/7
- Understands what the caller wants (booking, question, etc.)
- Automatically books appointments in the business's calendar
- Transfers the call to a human when necessary
2. Classification under the EU AI Act
The transparency obligations under Article 50 of the EU AI Act (Regulation (EU) 2024/1689) become applicable starting 2 August 2026 (per Art. 113 of the regulation). Vocalyy already proactively complies with these requirements, regardless of the date on which this page is consulted.
Under the risk-tier classification of the EU AI Act, the Vocalyy voice agent — used for customer interactions (bookings, service information) — falls under:
- Limited risk (Article 50) — an AI system that interacts directly with natural persons
- Main requirement: transparency — the caller must be informed that they are interacting with an AI system
Vocalyy is not:
- An unacceptable-risk AI system (prohibited)
- A high-risk AI system (recruitment, creditworthiness/credit scoring assessment, law enforcement, medical diagnosis, etc.)
- A standalone general-purpose AI (GPAI) system
3. How it works technically
Call flow:
- Call reception: The call reaches the Vocalyy agent via Telnyx (telephony/call-routing provider)
- Disclosure: The agent informs you that it is an AI system and, where applicable, that the call is being recorded
- Your voice → text: ElevenLabs converts your voice into text (speech-to-text), in real time
- Conversational processing: The text is sent to the Anthropic Claude model, which generates a response based on the instructions and script configured by the business you called
- Text → voice: The generated response is converted back into voice by ElevenLabs (text-to-speech) and played back to you
- Actions: If you requested a booking, the agent accesses the business's calendar and creates it
4. AI models used
- ElevenLabs — AI voice model, responsible for voice-to-text (speech-to-text) and text-to-voice (text-to-speech) conversion; it also hosts the audio recording of the call
- Anthropic Claude — the language model (LLM) that generates the content of the conversation and the agent's decisions (e.g., which response to give, which action to trigger)
Both are general-purpose foundation models — they are not specifically trained for Vocalyy. Their behavior is configured through text instructions (system prompts) specific to each client business, not through additional training of the models.
OpenAI is not and has not been used by Vocalyy for any voice-processing or conversational service.
5. What the agent can do
- Answer calls in Romanian (or other configured languages)
- Answer questions about the business (hours, services, prices)
- Book appointments in the calendar
- Confirm existing appointments
- Understand the caller's intent from context
- Transfer the call to a human on request
6. What the agent CANNOT do
- It does not make decisions with legal impact on you (it does not refuse a service, it does not issue legal contracts)
- It does not provide medical, legal, or financial advice
- It does not emotionally manipulate and does not use subliminal techniques
- It does not identify people through biometric voice recognition
- It does not assess your credit risk
- It does not perform behavioral profiling beyond the purpose of the call
- It does not handle medical or other emergencies — Vocalyy is exclusively a communication tool, not a medical, emergency, or advisory service
7. Known limitations
We are transparent about the technical limitations of the agent:
- It can make mistakes — AI models sometimes generate inaccurate responses ("hallucinations")
- It may not understand strong accents or background noise
- It does not have access to real-time information beyond what has been configured (it cannot search the internet)
- It does not remember previous conversations with the same caller (unless the business has explicitly enabled this feature)
- Latency may vary depending on network quality (typically 1-3 seconds)
- It operates on a best-efforts basis, not an obligation of result — the agent is configured and maintained with reasonable diligence, but we cannot guarantee a specific outcome in every conversation
8. Your rights as a caller
As a person calling a Vocalyy number, you have the right:
- To be informed that you are speaking with an AI system (we inform you at the start of the call)
- To request transfer to a human at any point during the call
- To hang up the call without consequences
- To request deletion of the recording and transcript — the request should be addressed to the business you contacted, as it is the controller of your data
- Not to be subject to automated decisions with legal impact on you (the agent does not make such decisions)
For full details on your rights under the GDPR and how callers' data is processed, see the Privacy Policy.
9. Call recording
Calls made through the Vocalyy agent may be recorded to ensure service quality, manage bookings, and for legal compliance. We inform you about the recording at the start of the call, where applicable.
It is important to understand who actually stores which data:
- The audio recording of the call is made and hosted by ElevenLabs (our AI voice provider) — Vocalyy does not store the audio file on its own servers.
- Vocalyy stores, in the dashboard of the business you called: your phone number, the call metadata (date, time, duration), and the full transcript of the conversation.
- The Vocalyy dashboard displays a "Download audio" button. Pressing this button downloads the audio recording directly from ElevenLabs to the client business's own device — Vocalyy's servers do not store and do not have persistent access to the audio file at any point. From the moment of download, the client business becomes the sole controller of that copy of the audio recording and is solely responsible for its security, storage, and any further processing.
If you do not want to be recorded or do not want the conversation transcript retained, you can hang up and contact the business through other channels (email, web form).
For the exact retention periods of this data, see the Retention Policy. For the full list of providers processing data on Vocalyy's behalf, see the List of Sub-processors.
10. AI model training
Your conversations are processed by ElevenLabs and Anthropic exclusively to generate the agent's responses in real time — not to "learn" new behaviors in real time.
[To be confirmed with ElevenLabs and Anthropic: the exact no-training/opt-out policy for data processed through the APIs used by Vocalyy] — Vocalyy will publish, once verified, the exact status of these two providers' training policies.
OpenAI is not used by Vocalyy for any service, so the question of training OpenAI models with callers' data does not arise.
11. Human oversight
Per the "human in the loop" principle of the EU AI Act:
- The business using the agent has dashboard access to all calls, metadata, and transcripts
- The caller can request transfer to a human at any point during the conversation
- Vocalyy monitors the technical operation of the agents for quality and safety
- We have escalation procedures for unexpected situations or reported technical errors
12. Complaints and appeals
If you believe the AI agent treated you incorrectly, or you have concerns about how your data was used:
- Contact directly the business you called — it is, as a rule, the controller of your data as a caller
- Contact Vocalyy at dpo@vocalyy.ro (privacy contact channel)
- If you are not satisfied with the response, you can file a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) for data-protection matters, or with the competent national authority for the EU AI Act (once designated in Romania) for matters related to the transparency of the AI system
13. Technical documentation
For B2B clients (the businesses using Vocalyy), we provide additional technical documentation on request:
- The AI system's technical data sheet
- Description of the data flow and the sub-processors involved (see the List of Sub-processors)
- User manual for implementers
- The Data Processing Agreement (DPA) — see the Data Processing Agreement
Request these documents at agent@vocalyy.ro.
14. Contact
- Technical questions: agent@vocalyy.ro
- Personal data / privacy: dpo@vocalyy.ro
- Vocalyy SRL — Romania
Related pages: Privacy Policy · Terms and Conditions · Retention Policy · Sub-processors · Data Processing Agreement
This document was drafted with computer assistance based on information available at the time of drafting and does not constitute legal advice from a licensed attorney. Vocalyy SRL recommends that this document be reviewed by an attorney specializing in data protection before publication, signature, or use in client relationships.