Consent & Data Protection (GDPR)

What kind of consent do end customers need to provide for telli to contact them?

No special form of consent is required for telli to contact end customers. Existing consent (e.g., via a contact form or lead funnel) or your current authorization for contact (e.g., legitimate interest) is sufficient.

Generally, there is currently no distinction between contact initiated by a human or an AI agent. This usually means you can maintain your existing consent for contact.

Do we need to obtain new consent for recording calls?

Call Recording

In the telli Web App under Settings, you can turn call recording on or off. If Call Recordings are switched off, no audio recording will be created, only a Real-Time Transcript.

If you enable recording, new consent must be actively given by the conversation partner before the recording begins, for example, through verbal agreement or by pressing a key on the phone. This consent must be obtained before the conversation. The most transparent approach would be to give the notice immediately before the conversation begins, but it can also be obtained earlier. Without this explicit consent, no conversations may be recorded.

Real-Time Transcript

A Real-time Transcript is always created automatically. The conversation is not stored as a recording; instead, the transcription occurs in real-time. For the transcript, there is the option from a data protection perspective to rely on legitimate interest (Art. 6 Para. 1 lit. f GDPR).

Does telli need to be included in our privacy policy?

Generally, yes. The GDPR requires that "recipients" or "categories of recipients" of personal data be named in the privacy policy. This includes telli as a service provider or data processor. For transparency, it's advisable to specifically name telli. If this would be too extensive due to many service providers used, it is sufficient to name categories, such as "AI tools for customer and lead management".

Can we also contact older existing leads whose consent was obtained before using telli?

Contact via telli is generally possible if the end customer's original consent for telephone advertising is explicit, voluntary, and specific enough for the intended use. The key factor is whether the existing consent clearly covers telephone advertising and is still effective (i.e., not revoked).

Essentially, you have the following options (the decision is ultimately yours):

Use Existing Consent:

If the scope and purpose of data processing by telli do not differ significantly from the consent originally obtained, you can continue to use this existing consent. Legally, this is well justifiable, especially if telli performs the same type of telephone advertising for which consent was originally given. However, it's important that the original consent was clearly formulated and explicitly included the use for telephone advertising.

Obtain New Consent (optional, but recommended if uncertain):

Alternatively, you can proactively ask your existing customers for renewed explicit consent, especially if there are doubts about whether the old consent is sufficiently specific or current. This significantly increases your legal certainty, even if it is not strictly legally required, as long as the original consent is still effective and clear enough.

Important Notes:

A legitimate interest is generally not sufficient for telephone advertising. Telephone advertising (especially in the B2C sector) is only permitted with explicit and effective consent. As soon as a customer revokes their consent, further calls must cease immediately. The customer does not need to provide a reason for the revocation. Also, ensure that consents do not remain valid indefinitely: They only justify calls within a reasonable period, especially as long as there is a demonstrable customer interest in the communication. The older the consent, the more critically you should check whether it is still sufficiently current and valid.

Example for inclusion in the Privacy Policy

The example template below is not legal advice, should not be published unchecked, and may need to be adapted to your specific use case.

"We use telli technologies GmbH for AI-powered telephone services to enable efficient communication within customer and employee processes. The provider is telli technologies GmbH, Knaackstraße 78, 10435 Berlin. The provider processes usage data (e.g., duration and time of calls, conversation histories), content data (e.g., customer inquiries, caller data), and meta-/communication data (e.g., device information, IP addresses) within and outside the EU.

The legal basis for processing is Art. 6 Para. 1 S. 1 lit. f GDPR. Our legitimate interest lies in providing our customers with efficient and secure customer service and assisting them as best as possible with their inquiries.

Data will be deleted as soon as the purpose for its collection ceases and no statutory retention obligations exist. Further information is available in the provider's privacy policy at https://hi.telli.so/datenschutz."

Note: The FAQ answers are based on the current legal situation and assessments (March 2025). As the EU Commission will publish detailed guidelines by February 2026 at the latest, some details listed here may change in the future.