Updated: September 21, 2026
Privacy Policy
This policy explains how TE Software Solutions LLC, St. Petersburg str. N 1, Tbilisi, Georgia ("we") processes personal data when you visit this website, create an account and use Coldfire CRM.
It covers the data for which we are the controller. For the data that our customers store and process in their CRM workspace, the customer is the controller and we act as processor under our Data Processing Agreement; see section 3.
1. Controller and Contact
Controller within the meaning of the GDPR is TE Software Solutions LLC, St. Petersburg str. N 1, Tbilisi, Georgia. For all privacy matters you can reach us at privacy@coldfire-crm.com.
2. What We Process, Why and on Which Legal Basis
Visiting the website
When you open our pages, the hosting provider processes technical data such as IP address, time, requested page, browser and operating system in server logs, to deliver the site and keep it secure (Art. 6(1)(f) GDPR). We do not use analytics or advertising trackers on this website.
Account and workspace
To register we process your name, email address, password (stored as a hash), company name and, if you sign in with Google, the identifier and email address Google provides. We use this data to create and secure your account, including verification emails and optional two-factor codes (Art. 6(1)(b) GDPR).
Subscription and payments
Subscriptions and telephony top-ups are sold by our reseller Paddle.com Market Ltd., which acts as Merchant of Record and is an independent controller for your payment data under its own privacy policy. We do not receive your full card details. From Paddle we receive the information we need to provide the Service and keep accounts: customer and subscription identifiers, plan, status, amounts, country and invoice references (Art. 6(1)(b) and (c) GDPR).
Using the application
We process usage and log data of users, such as sign-ins, IP addresses, device information and an audit log of security-relevant actions, to operate, secure and troubleshoot the Service and to enforce plan limits (Art. 6(1)(b) and (f) GDPR). Usage counters for the fair-use limits contain no call content.
Support and contact
If you contact us by email, through the contact form or the support chat, we process your message and contact details to answer it (Art. 6(1)(b) or (f) GDPR).
Service emails
We send emails that belong to the Service, for example verification, billing, usage and setup notices. We do not send marketing newsletters without your consent.
3. Data Our Customers Process in the CRM
Customers use the Service to manage their own leads and contacts, to make and record calls, to have calls transcribed and documented by AI, and to send and receive email. For this data the customer decides on purposes and means and is the controller. We process it only on the customer's instructions as processor (Art. 28 GDPR); the details are set out in our Data Processing Agreement.
If you are a person who was contacted by one of our customers and want to exercise your rights, please contact that customer. If you contact us, we forward your request to the customer where we can identify it.
Call recordings are stored in encrypted cloud storage in an EU region. Transcription runs on speech-recognition software that we operate ourselves in Germany. AI call documentation is generated from the transcript by an AI provider acting as our subprocessor; data sent through its API is not used to train models.
4. Recipients and Subprocessors
We use carefully selected service providers for hosting, storage, telephony, AI documentation and email delivery. The current list, including locations and transfer mechanisms, is published on our Subprocessors page (https://coldfire-crm.com/en/subprocessors). Beyond that we disclose data only where the law requires it or where it is necessary to assert or defend legal claims.
5. Transfers to Third Countries
We are established in Georgia; the application and its databases are hosted in Germany. Where providers process data outside the EU or EEA, the transfer is based on an adequacy decision, including the EU-U.S. Data Privacy Framework, or on the EU Standard Contractual Clauses. You can request a copy of the safeguards from us.
6. How Long We Keep Data
- Workspace data: for the duration of the subscription; after it ends, 60 days for reactivation or export (we remind you by email 7 days before), then deletion. Backup copies are overwritten in the regular backup cycle. Your user account stays so you can start a new workspace; we delete it on request.
- Call recordings, transcripts and other CRM content: until the customer deletes them or the workspace is deleted as described above.
- Billing records: as long as tax and commercial law requires; invoices are issued and kept by Paddle.
- Server and security logs: for a limited period, generally no longer than 90 days, unless needed to investigate an incident.
- Support requests: until the matter is closed, and afterwards as long as needed to document it.
8. Security
We protect data with transport encryption, role-based access control, logical separation of customer workspaces, daily backups and restricted administrative access. No system is completely secure; if a breach affects your data, we inform you as the law requires.
9. Your Rights
You have the right to access, rectification, erasure, restriction of processing, data portability and to object to processing based on legitimate interests. Where processing is based on consent, you can withdraw it at any time with effect for the future. To exercise your rights, write to privacy@coldfire-crm.com.
You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU member state where you live or work.
10. Children
The Service is aimed at businesses and is not intended for persons under 18. We do not knowingly collect data from children.
11. Changes to This Policy
We update this policy when the Service or the law changes. The current version is always available on this page; we announce material changes to customers by email.
12. Contact
Questions about this policy or about your data: privacy@coldfire-crm.com.
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