Privacy Policy
Last Updated: 19 February 2026
Summary: SantaCalls.ai is committed to protecting children's privacy. We collect minimal data, use it only to provide Santa calls, and delete it quickly. We never sell your data or use it for training AI models.
This notice sits alongside the main LEMA Logic Privacy Policy and covers SantaCalls-specific processing, including our use of AI tools for voice calls and gift recommendations.
1. Who We Are
SantaCalls.ai is operated by LEMA Logic Limited, a company registered on the Isle of Man.
- Company: LEMA Logic Limited (Company No. 137753C)
- Address: 30 Victoria Way, The Meadows, Castletown, IM9 1DX, Isle of Man
- Email: elf@santacalls.ai
- Data Protection Contact: hello@lemalogic.com
For the purposes of data protection law, LEMA Logic Limited is the "data controller" of the personal information we process.
2. Data We Collect
We collect only the information necessary to provide our service:
| Data Type | Purpose | Retention |
|---|---|---|
| Parent/Guardian Name | Identify account holder, consent verification | 30 days after last call |
| Child's First Name | Personalise Santa's call (Santa greets them by name) | 30 days after last call |
| Email Address | Send call summary and wish list | 30 days after last call |
| Phone Number | Initiate Santa's phone call (optional — not required for web calls) | 30 days after last call |
| Voice Recording | Generate call transcript via AI transcription | 30 days maximum |
| Call Transcript | Create wish list summary for parents; multiple versions may be generated for accuracy (see Section 6) | 30 days maximum |
| Consent Records | Legal compliance (consent text shown, timestamp, IP address, country) | 2 years |
| Marketing Preferences & Mailing List | Send info about other LEMA Logic AI services (opt-in only) | Until withdrawn (see note below) |
| Diagnostic Logs | Error monitoring, rate limiting, and debugging (may include IP addresses, call IDs, timestamps, and error messages) | 30 days |
Mailing list data retention: If you opt in to receive information about other LEMA Logic services, we retain your name and email address on our mailing list independently of your call data. This means your call data (voice recordings, transcripts, child's name, phone number) is still deleted within 30 days, but your mailing list subscription and contact details are retained until you unsubscribe. Every marketing email includes an unsubscribe link. You can also email hello@lemalogic.com to be removed at any time.
3. Legal Basis for Processing
We rely on different legal bases depending on the type of processing:
| Processing Activity | Legal Basis |
|---|---|
| Collecting registration data (parent name, email, child's name, phone number) | Consent (parental) |
| Voice recording and transcription | Consent (parental) |
| Conducting the Santa call (web or phone) | Contract performance |
| Sending email summary with wish list | Contract performance |
| Providing recording access, download, and sharing | Contract performance |
| Gift extraction and purchase links | Contract performance |
| Marketing communications (other LEMA Logic services) | Consent (separate opt-in) |
| Safety and quality reviews | Legitimate interest (child safety) |
| Anonymous aggregate analytics | Legitimate interest (service improvement) |
Where we rely on legitimate interests, we have assessed that these interests do not override your or your child's rights. Safety reviews directly serve the child's best interests by ensuring conversations remain age-appropriate, and analytics use only anonymous aggregate data with no personal identifiers.
4. How We Use Your Data
We use your information to:
- Enable your child to talk to Santa via web call (browser) or phone call
- Personalise the conversation (Santa will greet your child by name)
- Generate a transcript of the call using AI transcription services
- Clean and format the transcript using AI to correctly identify speakers (Santa, child, parent)
- Extract your child's Christmas wishes from the conversation using AI analysis
- Send you an email summary with wish list and gift recommendations
- Verify parental consent for calls to children
- If you opt in, send you information about other LEMA Logic AI products
- Improve our service (aggregate, anonymised data only)
Recording Access, Download & Sharing
After your child's call, we provide you with:
- Listen page: A unique URL where you can replay the call recording in your browser
- Download: The option to download the recording to keep permanently
- Sharing: You may share the listen page URL with family and friends (e.g. grandparents) at your discretion
The recording is automatically deleted from our servers after 30 days. After deletion, the listen page will display an expiry message and the recording will no longer be available. Any copies you have downloaded will remain on your device. Sharing the listen page URL is your choice — LEMA Logic is not responsible for onward sharing by recipients.
Safety and Quality Reviews
Call recordings and transcripts may be reviewed by authorised LEMA Logic personnel or AI tools for safety and quality assurance purposes. Access is restricted on a need-to-know basis and all access is logged. This includes:
- Ensuring conversations remain age-appropriate and safe for children
- Monitoring for technical issues or poor call quality
- Verifying that PII redaction is working correctly
- Improving the overall service experience
Important: While we may use AI to assist with safety and quality reviews, we NEVER use child data to train AI models. Voice recordings and call transcripts are deleted within 30 days. AI tools process data only to deliver the service and assist with reviews — no data is retained by AI providers for AI model training.
5. Children's Privacy (COPPA, UK AADC, GDPR Article 8)
Important: This service is intended for parents and guardians. Children do not browse or transact on this site. All interactions with children occur via supervised voice calls initiated by a parent/guardian.
Protecting children is our highest priority:
- Parental Consent Required: Only parents/guardians can request a Santa call. We do not collect data directly from children.
- Minimal Data Collection: We only collect the child's first name — no surnames, ages, addresses, or school information.
- No Confidential Data Expected: Children are speaking to Santa about Christmas wishes. We do not expect or solicit any confidential, sensitive, or personal information from children during calls.
- PII Redaction: If a child does happen to mention personal information during a call (such as an address, school name, or surname), our AI automatically detects and redacts it from the transcript before it is stored or emailed to parents. This redaction is applied across all transcript versions.
- Rapid Deletion: All call data (voice recordings, transcripts) is deleted within 30 days.
- No Tracking: We do not use cookies or tracking technologies that could identify children.
- No Marketing to Children: We never market directly to children or share their data with advertisers.
6. Data Sharing
We share data only with trusted service providers who help us operate SantaCalls.ai:
| Provider | Purpose | Location |
|---|---|---|
| Retell AI | Voice call processing and initial transcription | United States |
| Deepgram | High-quality transcription with speaker identification | United States |
| OpenAI | Transcript cleanup, speaker identification, wish list extraction, gift recommendations | United States |
| Resend | Email delivery (call summaries and wish lists) | United States |
| Cloudflare | Website hosting, backend processing, database storage, security | Global (DPA with SCCs in place) |
How AI Processes Your Call
After each call, the following automated pipeline runs to generate your wish list email:
- Step 1: Retell AI provides the initial voice call transcript
- Step 2: Deepgram re-transcribes the recording with speaker diarization for improved accuracy
- Step 3: OpenAI cleans the transcript, correctly identifies speakers (Santa, child, parent), and formats it
- Step 4: OpenAI analyses the cleaned transcript to extract Christmas wishes and generate gift recommendations
- Step 5: The summary email is sent to you via Resend
All providers are bound by Data Processing Agreements (DPAs) that contractually prohibit them from retaining or using your data for AI model training. We use paid business and API accounts (not free consumer tiers) with all providers, which provide enhanced contractual protections and enterprise-grade data handling commitments. We have verified that appropriate safeguards (Standard Contractual Clauses or equivalent) are in place for international transfers.
We never sell your data to third parties for marketing purposes.
7. Affiliate Links & Gift Recommendations
The wish list emails we send may contain affiliate links to products on Amazon UK and other retailers. If you purchase through these links:
- We receive a small commission (typically 4-8%)
- This helps us keep SantaCalls.ai free for families
- The price you pay is not affected
- We do not share your purchase data with anyone
You are under no obligation to use these links. They are provided purely as a convenience.
8. Your Rights
Under the Isle of Man Data Protection Act 2018, UK GDPR, EU GDPR, and US COPPA, you have the right to:
- Access: Request a copy of your personal data (including any data collected from your child)
- Rectification: Correct inaccurate data
- Erasure: Request deletion of your data ("right to be forgotten") — this covers all personal data including any mailing list entries, unless you tell us otherwise
- Restriction: Limit how we process your data
- Portability: Receive your data in a machine-readable format (you can also download call recordings directly from your listen page)
- Object: Object to processing based on legitimate interests
- Withdraw Consent: Withdraw consent at any time (this won't affect processing before withdrawal)
- Refuse Further Collection (COPPA): Parents may refuse to permit further collection or use of their child's information at any time
To exercise any of these rights, contact us at hello@lemalogic.com. We will respond within 30 days.
9. Data Security
We implement appropriate technical and organisational measures to protect your data:
- All data transmission is encrypted using TLS 1.3
- Data at rest is encrypted using AES-256
- Access to personal data is strictly limited to authorised personnel
- We use secure, SOC 2 compliant service providers
- Regular security reviews and updates
10. International Transfers
SantaCalls.ai uses AI systems and services operated by providers based in the United States. This means your data — including voice recordings, transcripts, and personal details submitted during registration — is transferred to and processed in the United States.
Specifically, the following US-based services process your data:
- Retell AI (voice call hosting and initial transcription)
- Deepgram (audio transcription with speaker identification)
- OpenAI (transcript cleanup, wish list extraction, gift recommendations)
- Resend (email delivery)
We have Data Processing Agreements (DPAs) in place with all of these providers. When transferring data outside the Isle of Man, UK, or EEA, we ensure appropriate safeguards are in place:
- Standard Contractual Clauses (SCCs) approved by the EU Commission
- UK International Data Transfer Agreement (IDTA) where applicable
- Data Processing Agreements with all providers contractually prohibiting use of your data for AI model training
- All providers engaged under paid business/enterprise terms (not free consumer tiers) with enhanced data protection and data handling commitments
11. Cookies
SantaCalls.ai uses only essential cookies required for the website to function. We do not use:
- Tracking cookies
- Analytics cookies that identify individuals
- Advertising or marketing cookies
- Social media tracking pixels
12. Changes to This Policy
We may update this Privacy Policy from time to time. If we make significant changes, we will notify you by:
- Updating the "Last Updated" date at the top of this policy
- Posting a notice on our website
- Emailing registered users (for material changes)
13. Complaints
If you're not satisfied with how we handle your data, you have the right to complain to the relevant supervisory authority:
Isle of Man
Information Commissioner
PO Box 69, Douglas, Isle of Man, IM99 1EQ
www.inforights.im
United Kingdom
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
ico.org.uk
14. Contact Us
For any questions about this Privacy Policy or our data practices:
- Email: hello@lemalogic.com
- General enquiries: elf@santacalls.ai
Thank you for trusting SantaCalls.ai! We take your family's privacy seriously and are committed to keeping the magic of Christmas safe and secure.