Last Modified: May 1, 2026
Nooks Communications, Inc. (“Nooks,” “we,” “our,” and/or “us”) values the privacy of individuals who use our websites, (including https://nooks.ai and https://app.nooks.in) and any of our other websites, applications, or services that link to this Privacy Policy (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share personal information from users of our Services (“Users”). By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes.
Nooks acts as a Processor on behalf of our Customers when they use our Services to manage their own sales workflows, call recordings, and customer data. For certain activities, including the training of proprietary models and the generation of aggregated cross-workspace insights (for the purposes of this Policy, “Platform Intelligence”), Nooks acts as a Controller. Platform Intelligence may include phone numbers paired with aggregated quality signals (such as connection rates and pickup likelihood), but does not include call recordings, prospect names, or any data linking a phone number to a specific Customer workspace.
1. WHAT INFORMATION DO WE COLLECT?
We may collect a variety of personal information from or about you or your devices from various sources, as described below.
A. Information You Provide to Us
Registration. When you register for an account to use our Services, we collect your personal information, including your name, email, job title, Company name, phone number, address and profile picture. If you register using your account with a third-party service (e.g., Microsoft, or Google), we collect your personal information from the applicable third-party service as discussed in “Platform Sign-On” under Section C below.
Payment. When you purchase our services, we collect information about the payment amount, billing address, contact information, date of purchase and purchase history. You may be required to provide your credit card details to Stripe, our third-party payment processor operating as our agent. Payment processing services by Stripe are subject to Stripe’s security and privacy policies found on Stripe’s website. As a condition of Nooks enabling payment processing services through Stripe, you authorize Nooks to share registration and transaction information related to your use of the payment processing services provided by Stripe.
Communications. If you contact us directly, we may receive additional personal information about you. For example, when you contact us for support, we will receive your name, email address, the contents of your message and recordings of calls with us. If you subscribe to our marketing communications, we will receive your email address.
Surveys. If you complete our surveys, we will collect your survey responses and any other personal information you include with your responses.
Marketing Forms: When you complete our marketing forms, we collect your personal information including your name, email, job title, Company name and phone number, in addition to information about how you plan to use our Services.
B. Information We Collect When You Use Our Services
Location Information. When you use our Services, we infer your general location information (for example, your IP address may indicate your general geographic region).
Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, web browser type, and operating system version.
Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with them, such as the length of time you spend on a page, objects such as hyperlinks you click on, and the dates and times of your visits.
Information from Cookies and Similar Technologies. We and our third-party partners may collect information using cookies, pixel tags, or similar technologies. This may include cookie identifiers that are necessary to provide certain features of the Nooks Service. Our third-party partners may use these technologies to collect information about your online activities over time and across different services. For more details about how Nooks uses these technologies, and your opt-out opportunities and other options, please see Nooks’ Cookie Policy.
Customer call recordings and meta-data for Nooks’ proprietary Artificial Intelligence (AI) Model training. If a User decides to record a third-party Customer Call, we may collect that call recording. The User bears all compliance responsibilities with respect to call recording with third-parties, and accordingly, is responsible for obtaining all necessary consents to do so. If a call is recorded, we may use that data solely to provide or improve the functionality of our Services. Users are able to opt out of the use of their call recordings for model training by emailing privacy@nooks.in. By opting out, Users may lose access to certain functionality of our Services. For clarification, the loss of certain functionality with our Services is strictly due to the nature of how Customer call recordings are used, and it is not punitive nor is it used to coerce an opt-in from the Customer.
Sequencing and Email Automation Data. When you use our sequencing and email automation features, we collect email body content, subject lines, reply content, message metadata, engagement data (such as opens, clicks, and bounces), send times, unsubscribe status, and mailbox synchronization metadata. This data is used to provide, operate, and improve our sequencing and email automation Services.
Platform Intelligence. We collect and aggregate call outcome data (such as whether a call connected, call duration, and call disposition), connection rates, and phone number quality signals across Customer workspaces to generate Platform Intelligence, including pickup likelihood scores, provider quality rankings, and phone number accuracy assessments. Platform Intelligence may include phone numbers paired with aggregated quality signals, but does not include call recordings, prospect names, or any data linking a phone number to a specific Customer workspace. Customers may opt out of contributing to and receiving Platform Intelligence through the product settings. By opting out, Customers will lose access to Platform Intelligence features such as pickup likelihood scores and quality rankings.
C. Personal Information We Receive from Third Parties
Platform Sign-On. When you register for our Services using a third-party account such as Google, or Microsoft, we receive your personal information, including your name, profile picture, and email address.
Partners. We may receive personal information about you from third parties such as data or marketing partners and combine it with other personal information we have about you.
Third-Party Data Providers. We license personal information, including phone numbers, email addresses, and professional contact data, from third-party data providers to support and improve our Services. This data is used in accordance with our agreements with those providers and applicable law.
D. Connected Accounts and Integrations
Google User Data (Gmail and Calendar). If you choose to connect your Google Account to Nooks to enable features such as syncing emails or viewing your calendar within the Nooks platform, Nooks will request your authorization through Google’s secure OAuth 2.0 process. Depending on the features you use, Nooks may request limited permissions to your: 1) Gmail (read, compose, send, and modify), and 2) Calendar data, solely to provide the requested functionality. These permissions also support our sequencing and email automation features, including composing, sending, and analyzing emails on your behalf. Nooks only accesses the information necessary to deliver these features and does not use Gmail or Calendar data for advertising, marketing, or AI/model-training purposes. Access is restricted to the minimum amount of necessary data, in relation to the purposes for which that data is processed. We do not transfer Google user data to third parties, except where needed to operate or maintain the Services, subject to data-processing agreements consistent with the GDPR and Google’s API Services User Data Policy, including the Limited Use Section. You can disconnect your Google Account at any time through your Google Account settings. Once disconnected, any cached Gmail or Calendar data associated with your account will be deleted within 7 days, unless a longer retention period is required by law or for legitimate business purposes (see Section 7).
Third-Party Platform Connectors. You may connect your Nooks account to third-party platforms through authorized connectors using OAuth 2.0 authentication. When connected, the third-party platform may access data within your Nooks workspace, scoped to your permissions, through Nooks’ External API (such as prospect data, call data, email data, sequence data, and related records). The connector is an access channel to existing data in your account and does not result in new data collection by Nooks. When you use a connector, your Nooks data transits through the third-party platform’s infrastructure and is subject to that platform’s terms and privacy policy. The third-party platform receives only the authorization credentials and request parameters necessary to facilitate the connection. You may disconnect a third-party AI platform at any time by revoking OAuth authorization through your Nooks account settings.
Browser Extension. If you install the Nooks browser extension, the extension may access data from third-party platforms you visit while using the extension, including professional profile data, contact information, and related business data. The extension collects this data at your direction to sync it with your Nooks workspace. The extension may also access authentication credentials associated with your connected third-party accounts solely to facilitate the data synchronization you initiate. Nooks uses this data to provide, operate, and improve our Services. Your use of the extension is subject to the applicable third-party platform's terms of service. You may uninstall the extension at any time.
2. HOW DO WE PROCESS YOUR INFORMATION?
We may use the personal information we collect:
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent in Section 10.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
We do not share or otherwise disclose personal information we collect from or about you except as described below or otherwise disclosed to you at the time of the collection.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information, in compliance with our obligations under the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. No mobile phone numbers collected by Nooks through inbound SMS or text message inquiries will be shared with third parties or affiliates for marketing or promotional purposes.
Controller-Side Service Providers. Where Nooks acts as a Controller (including for Platform Intelligence and for Nooks' own operational, analytical, and product improvement purposes), we may engage service providers to assist with analytics, performance monitoring, error tracking, product development tooling, and infrastructure management. These service providers process personal data on Nooks' behalf in its capacity as a Controller and are bound by contractual obligations regarding data confidentiality and security. This processing is governed by Nooks' obligations as a Controller under applicable data protection law and is separate from subprocessor arrangements governed by our Customers' Data Processing Agreements.
Onward Transfers. In the context of an onward transfer, Nooks is responsible for the processing of personal information it receives under the DPF Principles and subsequently transfers to a third party acting as an agent on our behalf. Nooks will remain liable under the DPF Principles if our agent processes your Personal Data in a manner inconsistent with the DPF Principles, unless Nooks is not responsible for the event giving rise to the damage.
The categories of third parties we may share personal information with are as follows:
As Required by Law. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (a) comply with lawful requests made by public authorities, including to meet national security or law enforcement requirements, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers. We may transfer your personal information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
Aggregated or de-identified data. We may disclose or use aggregated or de-identified Information. For example, we may share aggregated or de-identified information with prospects or partners for business or research purposes.
Prohibition on re-identification. We do not permit any third party to, attempt to re-identify any de-identified, aggregated, or anonymized data or otherwise associate such data with an identifiable individual, household, or device.
Cross-Workspace Platform Intelligence. Nooks generates Platform Intelligence by aggregating call outcome signals, connection rates, and phone number quality data across Customer workspaces. This intelligence, including pickup likelihood scores, provider quality rankings, and accuracy assessments, may be shared with other Customer workspaces to improve the accuracy and effectiveness of our Services. Platform Intelligence may include phone numbers paired with aggregated quality signals, but does not include call recordings, prospect names, or any data linking a phone number to a specific Customer workspace. Customers may opt out of contributing to and receiving Platform Intelligence through the product settings. For more information about the data used to generate Platform Intelligence, see Section 1(B).
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
We use cookies and other tracking technologies and offer you the option to manage these settings as described in our Cookie Policy. Some tracking technologies enable us to track your device activity over time and across devices and websites. While some browsers have incorporated Do Not Track or DNT preferences, we do not honor such signals from web browsers at this time. We do recognize Global Privacy Control (GPC) signals. GPC is a browser-based signal that allows you to communicate your choice to opt out of the sale or sharing of your personal information without making an individual request through our website. When we detect a GPC signal from your browser or device, we will automatically apply it as a request to opt out of the sale and sharing of personal information for that browser or device, consistent with applicable law. This opt-out applies to data shared through cookies, tracking technologies, and similar tools used for advertising and analytics. The GPC signal applies to the specific device and browser you use at the time you cast the signal and does not include Do Not Track signals.
6. DO WE OFFER AI-BASED PRODUCTS?
Our Services leverage AI to enhance sales productivity of sales professionals by transcribing conversations, summarizing key points, identifying follow-up actions, surfacing the right prospects at the right time, offering in-the-moment coaching, drafting and analyzing multi-channel sequences.
Nooks uses a combination of third-party AI tools and proprietary AI models to support key features of our Services. Proprietary non-generative models power features such as pickup detection (answering machine detection) and produce call outcome labels that feed into the Platform Intelligence; Platform Intelligence itself is generated through statistical aggregation, not AI processing (see Section 4). Third-party generative AI models power features such as email drafting, call summarization, coaching, and reply analysis; these models process data for inference only and are not trained on Customer data. The third-party AI tools are considered as subprocessors who are bound by Data Processing Agreements (DPAs) to strict contractual obligations about information security standards including compliance with regulations, data confidentiality and data access control. Nooks subprocessors are contractually prohibited from using any data obtained from Nooks (including any de-identified, aggregated, or anonymized data derived therefrom), for the purposes of training, fine-tuning, or otherwise developing any artificial intelligence (AI), machine learning (ML), or large language models (LLMs), including general-purpose models.
Sequencing content (such as email drafts, subject lines, and reply text) is not shared across Customer workspaces. Aggregated engagement signals from sequencing activity (such as channel performance and response rates) may be used to generate Platform Intelligence as described in Section 4.
All AI-generated outputs, including message drafts, call summaries, and coaching suggestions require human review before use. Nooks does not make solely automated decisions that produce legal or similarly significant effects for Users. In accordance with applicable laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), as amended by the CPRA, we:
7. HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary to provide our Services, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
When we have no ongoing legitimate interest or business need to process your personal information, we will either delete or anonymize such information. To the extent that this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
You may also opt out of the retention of your personal information by notifying us at privacy@nooks.in.
8. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no parts of our Services are directed to children under 16. If you believe that we have collected information about a child under 16, please contact us by emailing privacy@nooks.in so that we may delete the information.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access our Services within a secure environment.
10. SUPPLEMENTAL INFORMATION FOR THE EEA, SWITZERLAND, AND THE U.K.
Legal Basis for Processing: Please see Section 3 for the legal basis on which we rely for the collection, processing, and use of personal data.
Your Data Protection Rights: Under applicable data protection laws, you may exercise certain rights regarding your personal data.
You may exercise these rights by contacting us using the details provided below. Please note that we may refuse to act on requests to exercise data protection rights in certain cases, such as where providing access might infringe someone else’s privacy rights or impact our legal obligations.
International Transfers of Personal Data
Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see Section 4 - WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? above), in the United States, and other countries. If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.
We have implemented measures to protect your personal information, including by using the European Commission's Module 2 of Standard Contractual Clauses and UK International Data Transfer Addendum and Swiss Addendum to the EU SCCs (as applicable) for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request via email to privacy@nooks.in.
We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
Where necessary, we implement supplementary measures such as data encryption, pseudonymization, and strict access controls to ensure your personal data remains protected.
You may request more information about our international transfer safeguards by contacting us at: privacy@nooks.in.
Nooks complies with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF as set forth by the U.S. Department of Commerce. Nooks has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Nooks has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Nooks commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Nooks at: privacy@nooks.in.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Nooks commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you. A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means.
The Federal Trade Commission has jurisdiction over Nooks’ compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).
EU/ UK Representative
The contact details for our EU Representative for GDPR purposes are as follows:
Adam Brogden, Instant EU GDPR Representative Ltd
Email: contact@gdprlocal.com
Tel: +353 15 549 700
Address: INSTANT EU GDPR REPRESENTATIVELIMITED Office 2 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland
Reporting Link: https://nookscommunicationsinc.gdprlocal.com/eu
The contact details for our UK Representative for GDPR purposes are as follows:
Adam Brogden, GDPRLocal Ltd.
Email: contact@gdprlocal.com
Tel: +441 772 217 800
Address: GDPRLocal Ltd. 1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB
Reporting Link: https://nookscommunicationsinc.gdprlocal.com/uk
11. SUPPLEMENTAL INFORMATION FOR CALIFORNIA RESIDENTS
This section applies to California residents and supplements the information in this Privacy Policy with disclosures required under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).
Categories of Personal Information We Collect
Over the past 12 months, we have collected the following categories of personal information from California residents:
Sources of Personal Information
We collect personal information from the following sources:
Business and Commercial Purposes for Collecting Personal Information
We use the categories of personal information listed above for the following business and commercial purposes:
Categories of Third Parties with Whom We Share Personal Information
We share personal information with the following categories of third parties:
California Privacy Rights
California residents have the following rights regarding their personal information:
To exercise your rights, you may submit a request by:
We verify your identity before processing your request and may ask you to provide information associated with your account (such as your email address) to match against our records. You may designate an authorized agent to submit requests on your behalf. To do so, you must provide the authorized agent written permission to submit the request.
Sale and Sharing of Personal Information
We do not sell personal information for monetary consideration. However, we use certain third-party cookies and analytics tools on our website for cross-context behavioral advertising, which may constitute a "sale" or "sharing" under the CCPA.
Over the past 12 months, we may have "sold" or "shared" the following categories of personal information for advertising and analytics purposes:
We have "sold" or "shared" this information with the following categories of third parties:
You may opt out of the "sale" or "sharing" of your personal information by:
Once you opt out, we will not ask you to reauthorize the sale or sharing of your personal information for at least 12 months. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.
12. SUPPLEMENTAL INFORMATION FOR OTHER U.S. RESIDENTS
If you are a resident of a U.S. state with comprehensive privacy legislation other than California (including but not limited to Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Indiana, Kentucky, Maryland, Minnesota, and Rhode Island), you have the following rights regarding your personal information, subject to certain exceptions under applicable law:
To exercise these rights, contact us at privacy@nooks.in. We will respond to your request within the timeframe required by applicable law. You will be required to verify your identity before we process your request. Consumers can also designate an authorized agent to exercise these rights on their behalf.
13. DO WE MAKE UPDATES TO THIS POLICY?
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Last Modified” date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US?
If you have questions or complaints regarding this Policy or about the Nooks’ privacy practices, please contact us by email at privacy@nooks.in, or at:
Nooks Communications, Inc.
Attn: Privacy Team,
350 Bush Street 8th Floor, San Francisco, CA 94104