Compliance Framework
BigDogCalling.ai – General Data Protection Regulation(GDPR)
Effective Date: 2025-04-27
Last Updated: 2025-04-27
This document articulates the formal data governance and privacy compliance architecture implemented by BigDogCalling.ai, developed in full alignment with the General Data Protection Regulation (EU) 2016/679 (GDPR). It complements and expands upon the organization’s overarching Privacy Policy and is expressly intended for the protection of natural persons located within the European Union (EU), European Economic Area (EEA), United Kingdom (UK), and Switzerland. This policy elaborates the conceptual rationale, statutory foundations, procedural obligations, and operational controls governing the collection, use, dissemination, and transborder transfer of personal data across BigDogCalling.ai’s technological ecosystem.
For the purposes of this policy framework, a “data subject” refers to any identifiable natural person whose personal data is processed by BigDogCalling.ai. This includes, but is not limited to: platform users, commercial clients, recipients of AI-mediated voice communications, and individuals represented in prospecting databases curated for lawful marketing purposes.
1. Data Stewardship and Contact Protocols
BigDogCalling.ai operates primarily as a data controller, as defined by Article 4(7) of the GDPR, and may assume the role of data processor when acting on behalf of third-party data controllers under formalized Data Processing Agreements (DPAs). In all cases, BigDogCalling.ai is committed to principles of accountability, transparency, and data minimization. Data subjects are encouraged to initiate contact regarding any data governance inquiry, request for the exercise of data rights, or complaint using the channels outlined below:
BigDogCalling.ai
Email: info@bigdogcalling.ai
Mailing Address: 25 1ST AVE SW, STE A WATERTOWN, SD 57201-3507
A designated Data Protection Officer (DPO) or qualified delegate may be appointed to ensure compliance with applicable data protection statutes and to serve as the primary point of contact for supervisory authorities.
2. Legal Bases for Lawful Processing Activities
Pursuant to Article 6 of the GDPR, BigDogCalling.ai’s processing of personal data is grounded in one or more of the following legal justifications:
– Consent (Art. 6(1)(a)): Informed, unambiguous, and freely given consent by the data subject, documented through affirmative opt-in mechanisms.
– Contractual Necessity (Art. 6(1)(b)): Processing indispensable to the initiation, execution, or maintenance of contractual obligations, especially concerning delivery of AI voice services and customer support.
– Legal Obligation (Art. 6(1)(c)): Processing mandated by binding legal instruments, regulatory directives, or governmental obligations.
– Legitimate Interests (Art. 6(1)(f)): Processing that serves essential operational needs, such as cybersecurity incident response, service analytics, fraud prevention, or model training—provided that such interests do not override the rights and freedoms of the data subject.
Where multiple legal bases may apply, BigDogCalling.ai applies the principle of purpose limitation and ensures data subjects are informed accordingly.
3. Algorithmic Decision-Making and Systemic Autonomy
The deployment of AI systems by BigDogCalling.ai entails the use of natural language models, voice synthesis technologies, and probabilistic learning architectures for handling customer interaction workflows. These models function semi-autonomously, dynamically generating human-like responses based on probabilistic inference. While automation enhances scalability and responsiveness, BigDogCalling.ai recognizes the risk of unintended output and maintains procedural fail-safes and audit trails for accountability.
Human oversight is systematically embedded at all material stages, especially when decisions bear legal or significant personal consequences, thereby ensuring conformity with Article 22(1) GDPR and corresponding recitals. No individual shall be subject to a decision based solely on automated processing without the availability of recourse to meaningful human intervention, except under the limited exemptions outlined in Article 22(2).
4. Transnational Data Transmission Protocols
In circumstances where personal data is transferred to jurisdictions outside the EEA, including to countries that have not been recognized by the European Commission as ensuring an adequate level of data protection, BigDogCalling.ai implements a multilayered compliance strategy. This includes:
– Execution of Standard Contractual Clauses (SCCs) as published by the European Commission;
– Supplementary measures such as encryption-at-rest, access controls, and localized data storage;
– Periodic risk assessments and legal due diligence concerning third-country surveillance laws and potential governmental access;
– Ongoing contractual oversight to ensure that onward transfers by subprocessors remain within the bounds of the original safeguards.
These measures are enforced in light of the CJEU’s jurisprudence in Schrems II and subsequent regulatory guidance from the European Data Protection Board (EDPB).
5. Rights of the Data Subject
Under Chapter III of the GDPR, data subjects possess a suite of enforceable rights with respect to the personal data held by BigDogCalling.ai. These include:
– Right of Access (Art. 15): The right to obtain confirmation as to whether personal data is being processed, along with associated metadata and the purposes of processing.
– Right to Rectification (Art. 16): The right to request correction of inaccurate personal data or supplementation of incomplete data.
– Right to Erasure (Art. 17): The right to have personal data erased under certain legal conditions, also known as the “right to be forgotten.”
– Right to Restrict Processing (Art. 18): The right to request the temporary suspension of data processing where accuracy is contested, processing is unlawful, or data is no longer needed.
– Right to Object (Art. 21): The right to object to processing grounded in legitimate interests or for direct marketing purposes, triggering an immediate balancing test by the controller.
– Right to Data Portability (Art. 20): The right to receive personal data in a structured, commonly used, and machine-readable format, and to have that data transmitted directly to another controller, where technically feasible.
Requests may be subject to identity verification protocols. BigDogCalling.ai endeavors to respond to data rights requests within the statutory period of one calendar month, subject to permissible extensions for complex cases.
6. Right to Lodge a Complaint
If a data subject believes that BigDogCalling.ai’s data processing activities infringe upon their rights under the GDPR or fail to comply with applicable data protection obligations, they are entitled to lodge a formal complaint with a supervisory authority. This authority may be located in the data subject’s country of residence, place of employment, or jurisdiction of the alleged violation. Contact details for relevant authorities are available via the European Data Protection Board (EDPB) website.
BigDogCalling.ai encourages data subjects to seek internal resolution where feasible and commits to cooperating fully with oversight bodies.
7. Policy Revision and Accountability Mechanisms
This GDPR Compliance Framework is subject to dynamic revision in response to legislative amendments, jurisprudential developments, technological evolution, and organizational restructuring. BigDogCalling.ai maintains a structured policy lifecycle, including periodic review, internal audits, and version control mechanisms.
Substantive modifications to this framework will be clearly indicated via update notifications and may necessitate renewed consent where legal grounds change materially. BigDogCalling.ai’s commitment to privacy-by-design and default underpins all enhancements to this policy, ensuring continuity with Article 25 GDPR and aligned best practices for organizational accountability.