Skip to content

Privacy Policy

Last updated November 3, 2026 · Zentient AI, LLC

Coldspark is made by Zentient AI, LLC ("we", "us"). This policy covers the Coldspark website, web app and iPhone app. We're the data controller for the personal data described here. Questions go to coldspark@zentient.ai.

1. What we collect

  • Account: your name, email address and password (stored hashed), or the name and email Google or Apple shares if you sign in with them. For each signed-in device we keep the IP address and browser or device type to keep your sessions secure.
  • Seller profile (optional): your company, what you sell and who you sell to.
  • Personas you create: their names, backstories, objections, voices and any avatar image link you add.
  • Practice calls: your microphone audio during a call, the transcript, the scorecard, the outcome and how long it lasted. On plans with recordings (Pro and Team), an audio recording of both sides of the call.
  • Persona memories: the notes each persona keeps about you after a call (your name, company, what you promised, how it went) and a rapport score.
  • Teams: team names, members, roles, invitations and practice assignments.
  • Billing: your plan, its status and renewal dates, and minutes used. Payments are taken by Apple or by Stripe through RevenueCat; we never see your card details.
  • Usage data: the pages and screens you view, the features and buttons you use, and what happens on calls and purchases (for example a call's length, outcome and score, or that you started a checkout), plus errors you run into. It never includes your audio, transcripts or what you type into personas. With it we record your app version, browser or device type, operating system, screen size, language, time zone, the country your IP address is in (not the address itself), the site that sent you to us and any campaign tags in the link. If you're signed in, it's linked to your account.
  • A random ID that ties your visits together: a first-party cookie (cs_vid) on coldspark.app and app.coldspark.app, and a value stored in the iPhone app. A second cookie (cs_utm) remembers the campaign tags of the link that first brought you to us.
  • Error reports: when something goes wrong in our servers or the iPhone app, a report of the error: what failed and where in our code, the app version, the device and operating system type, and what the server or app was doing just before (such as which request or screen). Server reports can include the ID of the call or record involved. We set them up to leave out your account details, cookies, audio, transcripts, persona text, sign-in codes and what you send in requests.

The microphone is only used during a practice call. Coldspark has no ads and no advertising trackers. Usage data is collected by our own code, isn't used to track you across other companies' apps or websites, and we don't sell your personal information.

2. How we use it

  • To run practice calls, play the prospect, score your calls and let personas remember you.
  • To run your account, teams and subscription, and send account emails (verification, password resets, team invitations).
  • To keep Coldspark safe: rate limits, abuse prevention and reviewing personas published to the community.
  • To understand how Coldspark is used, find what's broken or confusing, and decide what to improve.
  • To find and fix errors and crashes.
  • To meet legal, tax and accounting obligations.

If GDPR or UK GDPR applies to you, our legal bases are: performing our contract with you (running the service), our legitimate interests (security, abuse prevention, moderation, fixing errors and improving Coldspark from usage data), legal obligations, and your consent where we ask for it (such as microphone access, which you can turn off in your device settings).

3. How AI processes your data

Coldspark is built on AI. When you use it, your data is sent to these providers, who process it for us:

  • Speech recognition: during a call, your voice is streamed to a speech-to-text model run by Cloudflare (Workers AI) to turn it into text.
  • OpenAI: the call transcript, the persona, your seller profile and what the persona remembers about you are sent to OpenAI's models to write the prospect's replies, score the call and update the persona's memory. They also generate personas you describe, and review personas and avatars published to the community.
  • Voices by ElevenLabs and Speechify: the prospect's lines are sent to one of them to be spoken aloud. They receive what the prospect says, not your voice.

Scorecards are coaching feedback. They don't make decisions about you with legal or similarly significant effects. AI output can be wrong.

4. Who we share it with

We use these service providers. They process your data on our behalf and only to provide their service:

  • Cloudflare, Inc. (US): hosting, database, recording storage, speech recognition, AI request routing and email delivery.
  • OpenAI, L.L.C. (US): AI models, as described above.
  • ElevenLabs, Inc. (US) and Speechify, Inc. (US): voices.
  • RevenueCat, Inc. (US): subscriptions and purchase records.
  • Stripe, Inc. (US): card payments on the web, through RevenueCat.
  • Functional Software, Inc. (Sentry) (US): error and crash reports from our servers and the iPhone app. It sees the IP address of the device or server that sends a report.
  • Click City: stores and analyzes usage data, with your account's name, email and plan so it can be tied to your account. It receives it from our servers, never directly from your browser or device.

Apple handles App Store purchases under its own privacy policy. If you sign in with Google or Apple, they share your name and email with us. Our websites load fonts from Google Fonts, which sees your IP address.

We also share data:

  • With your team, as described in section 5.
  • With other Coldspark users when you publish a persona, as described in section 6.
  • When the law requires it, or to protect the rights and safety of our users or others.
  • With a buyer or successor if Zentient AI, LLC or Coldspark is sold or merged, under this policy.

5. Teams

On a team plan, the team's owners and admins see a dashboard with each member's calls, minutes, average score and meetings booked. They can also open calls billed to the team plan, including transcripts, scorecards and recordings. That access ends when you leave the team. Calls on your personal plan aren't visible to your team.

6. Community personas

When you publish a persona to the community library, it's reviewed by AI and then shown to every Coldspark user with your name as its author. Other users can clone it, and their copies stay after you unpublish yours or delete your account. Don't put personal information about real people in a persona.

7. How long we keep it

  • Calls, transcripts, scorecards and recordings: for the retention period of the plan that paid for the call (Free 14 days, Pro 365 days, Team 730 days). If a paid plan ends, its retention continues for 30 days.
  • Account, seller profile, personas and persona memories: until you delete them or your account.
  • Sign-in sessions: they expire after 30 days without use.
  • Error reports: Sentry deletes them automatically after at most 90 days.
  • Usage data: as long as it's useful for improving Coldspark. Deleting your account doesn't remove it automatically; email us and we'll delete the usage data linked to your account.
  • Purchase records: as long as tax and accounting law requires.

8. Your choices and rights

  • Delete any call, delete a single memory, or clear everything a persona remembers about you, in the app.
  • Delete your account in the iPhone app (Profile → Delete account) or on the web (Settings). This removes your personas, memories, calls, recordings and subscription records. It doesn't cancel an App Store subscription; cancel that in your Apple ID settings.
  • Edit your name on the web (Settings) and your seller profile in either app.
  • Block or clear cookies in your browser to stop the website from linking your visits. You can object to usage data being collected by emailing us.
  • Email coldspark@zentient.ai to get a copy of your data, correct it, restrict or object to how we use it, or ask any question. We answer within 30 days.

EU, EEA and UK: you have the rights of access, correction, deletion, restriction, portability and objection, and you can complain to your local data protection authority.

California: you have the right to know what we collect, and to access, correct and delete it. We don't sell or share personal information for cross-context behavioral advertising, and we won't treat you differently for using your rights.

9. International transfers

We and our providers process data in the United States and other countries. Where data leaves the EU, EEA or UK, we rely on safeguards such as the European Commission's Standard Contractual Clauses in our providers' data processing terms.

10. Security

Data is encrypted in transit and at rest, passwords are hashed, and access is limited to what each part of the service needs. If a breach puts your data at risk, we'll tell you and the relevant authorities as the law requires.

11. Children

Coldspark is for people 18 and over. We don't knowingly collect data from anyone younger. If you think a child has an account, email us and we'll delete it.

12. Changes

If we change this policy, we'll update the date at the top. For material changes we'll tell you in the app or by email before they take effect.

13. Contact

Zentient AI, LLC, coldspark@zentient.ai.