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Data Processing Agreement (DPA)

Last updated: July 19, 2026
You accept this DPA together with the Terms of Service and Privacy Policy at signup (clickwrap) — no signature required.

1. Roles

You (the business customer) are the business/controller. FirstCue, LLC is your service provider/processor. FirstCue processes personal information — including call recordings, transcripts, and caller intake data — solely to provide the service to you. Terms such as "personal information," "sell," "share," "service provider," and "verifiable consumer request" have the meanings given in the California Consumer Privacy Act (CCPA) and its regulations, including regulation §7051.

2. FirstCue's obligations (CCPA §7051)

  • Will not sell or share the personal information.
  • Will process only for the specified business purposes (answering, recording, transcribing, intake, routing, notifications, support, security, billing, and operating/improving the service for you) and no other purpose.
  • Will not use the personal information outside the direct business relationship with you.
  • Will provide the same level of privacy protection the CCPA requires of businesses.
  • Will notify you if it determines it can no longer meet these obligations.

3. Audit & monitoring

You may take reasonable steps to monitor FirstCue's compliance — including manual reviews, automated scans, or requesting FirstCue's assessments/attestations — on reasonable notice.

4. Assisting with consumer requests

FirstCue will assist you in responding to verifiable consumer requests (to know/access, delete, and correct) by providing, deleting, or correcting the relevant consumer's personal information in FirstCue's systems within the time the CCPA allows.

5. Subprocessors (flow-down)

FirstCue may use subprocessors (telephony/voice, payments, email, and cloud infrastructure) but binds each by written contract to data-protection and use-limitation obligations at least as protective as those here. FirstCue remains responsible for its subprocessors.

6. Security

FirstCue maintains reasonable administrative, technical, and physical safeguards appropriate to the personal information, including encryption in transit and access controls, and will notify you without undue delay after becoming aware of a security incident affecting the personal information.

7. Return or deletion

On termination or your request, FirstCue will delete or return the personal information it processes for you, except copies required to be retained by law, which remain subject to this DPA.

8. Acceptance

You accept this DPA at signup by checking "I agree" together with the Terms of Service and Privacy Policy (clickwrap). No separate signature is required. Enterprise clients may request a separately signed copy.

9. Contact

Questions about this DPA? Email privacy@firstcue.ai. FirstCue, LLC.

Terms of Service →   Privacy Policy →

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