PRIVACY POLICY

Last updated October 21, 2026



This Privacy Notice for Nikita Filippov ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
  • Engage with us in other related ways, including any marketing or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].


SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we collect any information from third parties? When you choose supported third-party sign-in, we receive the account information described in sections 1 and 7. Service-provider processing and website advertising attribution are described in sections 4 and 5. information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? No electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.


TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO WE MAKE UPDATES TO THIS NOTICE?
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?


1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
  • email addresses
  • passwords
  • audio recordings, images, and campaign text that users choose to submit
  • names
  • contact preferences
  • contact or authentication data
  • reference voice samples and session excerpts that users explicitly choose to save for speaker attribution
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
  • biometric data
Payment Data. Payments are handled by Stripe. We process purchase and transaction information relating to payments made through Stripe. You may find Stripe’s privacy notice here: https://stripe.com/privacy.

Third-Party Login Data. When you choose a supported third-party sign-in method, we receive account information from that provider to create or link your EpicEcho account and sign you in. Google sign-in supplies an account identifier, email address and verification status, and available name and profile-photo information. Where Sign in with Apple is available, we process an Apple account identifier, email verification information, an email address when supplied, and any name supplied through the sign-in flow. The email address may be an Apple private relay address. Authentication tokens and authorization codes support sign-in; encrypted Apple authorization information supports account disconnection and deletion. These sign-in flows do not request your friends list or contacts. HOW DO WE HANDLE YOUR SOCIAL LOGINS?.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
  • Mobile Device Access. We request microphone access for session recording. You can change microphone permission in your device settings. Notification permission is separate, as described below.
  • Mobile Device Data. We process network and client information used in authentication and operation of the service, including IP addresses and user-agent information. Web push subscriptions include a delivery endpoint and encryption information and may include user-agent information. If you enable iOS notifications, an APNs device push token can be associated with your account to deliver notifications. Notification preferences and subscription lifecycle information support delivery and removal. A push token is a notification-delivery identifier.
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We process network and client information used to authenticate requests and operate the Services, including IP addresses and user-agent information. Optional website analytics and advertising attribution depend on the controls described in section 5. Shared backend operational processing is described there separately. Account-associated and request information can relate to an identifiable person.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:
  • Log and Usage Data. Shared backend services may process operational events and error information when server telemetry is configured. Such information can include account and request identifiers, a redacted request path, method, status and exception information. Optional website usage analytics, session replay and error processing are subject to website consent controls and application filtering.
  • Network, client and notification-delivery information. We process IP addresses and user-agent information for authentication and operation of the service. Web push subscriptions include a delivery endpoint and encryption information and may include user-agent information. If you enable iOS notifications, an Apple Push Notification service (APNs) device push token can be associated with your account to deliver notifications. Notification preferences and subscription lifecycle information support delivery and removal. A push token is a notification-delivery identifier.

Google API

Our use of information received from Google APIs will adhere to 
Google API Services User Data Policy, including the Limited Use requirements.

Information collected from other sources

In Short: We receive account information when you choose supported third-party sign-in.

When you choose a supported third-party sign-in method, we receive account information from that provider to create or link your EpicEcho account and sign you in. Google sign-in supplies an account identifier, email address and verification status, and available name and profile-photo information. Where Sign in with Apple is available, we process an Apple account identifier, email verification information, an email address when supplied, and any name supplied through the sign-in flow. The email address may be an Apple private relay address. Authentication tokens and authorization codes support sign-in; encrypted Apple authorization information supports account disconnection and deletion. These sign-in flows do not request your friends list or contacts.

These sign-in flows do not request friends lists or contacts. The provider controls its own processing under its privacy notice. Website advertising attribution, where consent and configuration permit it, is described in section 5. withdrawing your consent.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. (Retention period: For as long as needed for account authentication, recovery, and account management, subject to deletion requests. Limited records may remain after account access ends while external cleanup or shared-authorship review is pending, or where retention is required by law. Shared history may be anonymized.)

    Session audio and speaker attribution. Where this feature is available, you can choose to save a short recording of your voice for a campaign or explicitly confirm and save excerpts of your voice from a session recording. We associate the reference sample with your account and campaign and record your consent. Authorized session audio and reference samples may be processed by Modal Labs to compare voice characteristics and assist identification of who spoke. The processing produces speaker segments and similarity results; we store speaker assignments and matching results with the session. A game master can also assign or correct speaker names. A game master's assignment does not by itself save a reference voice sample for that person.

    Recording and processing choices. Microphone permission, agreement at the gaming table and permission to send material for AI processing are separate choices. Local recording and recovery do not by themselves submit a recording for AI processing. An identity clear or sign-out does not by itself authorize deletion of local recordings. Account-deletion cleanup follows acceptance of the deletion operation.

    Release-status qualification. The local recording recovery and account-deletion behavior described here reflects the release candidate implementation. Deployment and cleanup scheduling must be verified before this draft is published.

  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

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.
  • 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.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations
  • We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

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. The providers and processing purposes are described below and in the relevant sections of this notice.

The third parties we may share personal information with are as follows:
  • Advertising, Direct Marketing, and Lead Generation
Reddit Ads
  • AI Service Providers
OpenAI, Anthropic, Google Cloud AI and ElevenLabs
  • Allow Users to Connect to Their Third-Party Accounts
Google account, Discord account and Telegram account
  • Cloud Computing Services
DigitalOcean and Modal Labs
  • Communicate and Chat with Users
Resend
  • Functionality and Infrastructure Optimization
Termly.io and Apple Push Notification service
  • Invoice and Billing
Stripe
  • User Account Registration and Authentication
Google Sign-In and Sign in with Apple
  • Web and Mobile Analytics
PostHog
  • Website Performance Monitoring
Better Stack

We also may need to share your personal information in the following situations:
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

Website and iOS processing. On the website, optional PostHog analytics operates only when the website's consent controls permit it. It can process usage events, account-associated information, session replay and error information, subject to the application's filtering. Reddit advertising conversion reporting is limited to Reddit-attributed activity with advertising consent. Depending on the event, reporting may include hashed identifiers, click and conversion identifiers, and user-agent information. These functions support analytics and conversion measurement; this description does not mean that advertisements are displayed inside EpicEcho.

The iOS client disables the optional client-side PostHog analytics integration and includes native-origin safeguards for advertising conversion reporting. Shared backend services may separately process operational events and error information through PostHog when server telemetry is configured, including for requests from the iOS app. Such information can include account and request identifiers, a redacted request path, method, status and exception information. Disabling client-side analytics does not disable all backend processing.


We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements or to tailor advertisements to your interests. The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including OpenAI, Anthropic, Google Cloud AI and Modal Labs. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:
  • AI-assisted drafting and organization of authorized submitted campaign material, search and answers, summaries, recurring campaign quizzes, and moderation where the relevant processing permission applies
  • Transcription of authorized submitted session audio and narration from authorized campaign text
  • Speaker separation and comparison with voluntarily saved reference voice samples to assist speaker attribution

How We Process Your Data Using AI

Our AI Products process authorized submitted material for the purposes described in this notice. The provider and purpose depend on the feature, including transcription, narration, AI-assisted campaign material and speaker attribution.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: Supported third-party sign-in supplies account information for authentication and account linking.

When you choose a supported third-party sign-in method, we receive account information from that provider to create or link your EpicEcho account and sign you in. Google sign-in supplies an account identifier, email address and verification status, and available name and profile-photo information. Where Sign in with Apple is available, we process an Apple account identifier, email verification information, an email address when supplied, and any name supplied through the sign-in flow. The email address may be an Apple private relay address. Authentication tokens and authorization codes support sign-in; encrypted Apple authorization information supports account disconnection and deletion. These sign-in flows do not request your friends list or contacts.

We use this sign-in information for authentication, account linking and the account functions described in this notice. Please review the relevant sign-in provider’s privacy notice for its own processing and privacy controls.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). If you are located in the EU or UK, see section "HOW DO WE PROCESS YOUR INFORMATION?" for our retention periods by purpose.

Reference voice samples. A saved reference sample remains until it is removed through the applicable account or campaign controls. Turning the feature off does not itself delete an existing sample. Removing a reference sample does not automatically remove past session recordings or names already attached to them. File cleanup may require retries.

Voice review excerpts. Session excerpts used for reviewing voices are available for up to 30 days. Access through newly issued signed links stops when they expire; expired files are processed by the cleanup worker, which may need retries.

Session recordings. Retention of uploaded session audio follows the campaign's recording-retention setting and applicable operational retention configuration. Removal after processing or expiry is performed by cleanup operations and may require retries.

Completed account-deletion operational records. The account-deletion implementation clears the encrypted operational cleanup payload when an operation completes. Encrypted identity information used for status access and recovery, together with the operation journal, is retained for 30 days after completion and then becomes eligible for purge. Pending operations are excluded from that completed-record purge.

Shared authorship / pending cleanup. Some information can remain after account access ends while external cleanup or shared-authorship review is pending. Shared history may be anonymized. The deletion flow provides status and recovery mechanisms; it does not promise a maximum completion time.

Release-status qualification. These cleanup details describe the candidate implementation; actual deployed deletion and retention schedules remain to be verified before publication.

When personal information is no longer needed for the purposes described in this notice, we delete or anonymize it, subject to applicable retention requirements. Deletion from active systems does not necessarily remove copies from backups at the same time. For questions about retention or a deletion request, contact [email protected].

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

No electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that unauthorized third parties will never access, steal, or modify your information. You should only access the Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at [email protected].

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018.

How to contact us:
What happens after you complain
  • We will acknowledge your complaint within 30 days of receiving it.

  • We will investigate without unjustifiable or excessive delay.

  • We will keep you informed of progress and explain the outcome.
If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office, the UK supervisory authority.
  • Website: ico.org.uk/make-a-complaint

  • Helpline: 0303 123 1113

  • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:
  • Log in to your account settings and update your user account.
  • Contact us using the contact information provided.
Account-deletion cleanup follows acceptance of the deletion operation. Some information can remain after account access ends while external cleanup or shared-authorship review is pending. Shared history may be anonymized. The deletion flow provides status and recovery mechanisms; it does not promise a maximum completion time. See section 8 for differentiated retention and the release-status qualification for this candidate implementation.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at [email protected].

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "
WHAT INFORMATION DO WE COLLECT?"

CategoryExamplesCollected
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

YES

B. Personal information as defined in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information

NO

C. Protected classification characteristics under state or federal law
Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data

NO

D. Commercial information
Purchase and transaction history relating to payments through StripeYES
E. Biometric information
Voiceprints used for speaker recognition during beta testing within one campaignYES
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

YES

G. Geolocation data
Device location

NO

H. Audio, electronic, sensory, or similar information
Images and audio, video or call recordings created in connection with our business activities

YES

I. Professional or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

NO

J. Education Information
Student records and directory information

NO

K. Inferences drawn from collected personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

NO

L. Sensitive personal InformationAccount login information and reference voice samples used for speaker identification, where used

YES

Historical collection during the preceding twelve months included purchases through Stripe and voiceprints used for speaker recognition in beta testing within one campaign. These collection facts do not by themselves identify the recipients of past disclosures or establish sale or sharing for advertising.


We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
  • Category A - For as long as needed for account authentication, recovery and the requested service, subject to deletion requests and the retention exceptions in section 8.
  • Category D - For as long as needed to administer purchases and transactions through Stripe, subject to deletion requests and the applicable retention exceptions described in section 8.
  • Category E - Reference voice samples remain until removed through the applicable account or campaign controls; file cleanup may require retries. Removing a sample does not automatically remove past session recordings or speaker names. See section 8.
  • Category F - Retention depends on the processing purpose and operational retention configuration, subject to deletion requests and the retention exceptions in section 8. The applicable analytics and provider retention settings require confirmation before publication.
  • Category H - For as long as needed to provide the requested service, subject to deletion requests and the retention exceptions described in this notice.
  • Category L - For as long as needed for account authentication and recovery. Reference voice samples used for speaker identification follow the reference-sample retention criteria in section 8. These uses remain subject to deletion requests and the retention exceptions described in this notice.

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

We collect and share your personal information through:
  • Reddit Conversions API (server-side conversion events)
Will your information be shared with anyone else?

We may disclose your personal information to the service providers described in the section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" for the processing purposes described in this notice.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
  • Category A. Identifiers

  • Category F. Internet or other electronic network activity information

  • Category H. Audio, electronic, visual, and similar information

  • Category L. Sensitive personal information
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

During the preceding twelve (12) months, we disclosed identifiers (Category A) and internet or other electronic network activity information (Category F) to Reddit Ads for advertising attribution and conversion measurement. Our Reddit integration sends signup and first-session-upload conversion events, event times and conversion identifiers. Where available, it includes hashed email addresses and account identifiers, a Reddit click identifier, and, for signup events, a hashed IP address and browser user-agent information. These are advertising event details; session recordings and voice samples are not fields in these conversion events.

The advertising recipient category for these disclosures is advertising, direct marketing, and lead generation.

The recipient of these advertising disclosures is:
  • Advertising, Direct Marketing, and Lead Generation
Reddit Ads

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
  • Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
  • Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
  • Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
  • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at [email protected], or by referring to the contact details at the bottom of this document.

You can opt out from the selling of your personal information, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:
  • offer you the products or services that you want
  • respond to or help with your requests
  • manage your account with us
  • confirm your identity and protect your account
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

General enquiries: [email protected]
Complaints (complete POPIA/PAIA form 5): [email protected] & [email protected]

15. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, 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 Notice frequently to be informed of how we are protecting your information.

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:

Nikita Filippov
21 Furlong Way, Great Amwell
Great Amwell
Ware, Hertfordshire SG12 9TE
United Kingdom

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.