Privacy Policy

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we may collect and may have collected over the past 12 months.

Categories of Sources of Personal Data

We may collect Personal Data about you from the following categories of sources:

Our Commercial or Business Purposes for Collecting or Disclosing Personal Data

Other Permitted Purposes for Processing Personal Data

Additionally, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Smooth AI or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

De-Identified Data

We may create de-identified, anonymized data ("De-Identified Data") from the Personal Data we collect so that it does not identify you. We may use such De-Identified Data for our lawful business purposes, including to analyze, build and improve the Services and promote our business. For clarity, Smooth AI does not use De-Identified Data to train AI models.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We May Disclose Your Personal Data

We may disclose your Personal Data to the categories of service providers and other parties listed in this section.

Cookies

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data — usually text files — placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies can also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services' content for those who engage with our advertising.

When you first visit our Services, you will be presented with a Cookie Consent Manager or banner that allows you to provide or withhold your explicit consent for non-essential Cookies (such as Performance and Analytical Cookies). You can update your preferences or withdraw your consent at any time through the Cookie settings on our website. Alternatively or additionally, you can decide whether or not to accept Cookies through your internet browser's settings. Please note that if you decline or disable certain Cookies, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work properly.

To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit allaboutcookies.org or ico.org.uk/for-the-public/online/cookies if you are located in the European Union.

Data Storage and Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. We store your Personal Data in Google Cloud Platform ("GCP") servers. All Personal Data is encrypted at rest and in transit using GCP's encrypted database system. Additionally, we implement a variety of security measures including firewalls, virtual private cloud (VPC) setups, and anti-virus/malware protection to help protect your Personal Data. You can also help protect your Personal Data by appropriately limiting access to your computer or device and browser, and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. In the event of a data breach that compromises your Personal Data, we will notify you and any applicable regulatory bodies without undue delay and within the timeframes required by applicable law (such as within 72 hours where required by the GDPR).

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider factors such as our purposes for collecting and the sensitivity of such data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

• Audio data is never recorded or stored. Audio is processed transiently in memory solely for the purpose of generating a real-time text transcript and is permanently discarded immediately upon transcription completion.
• Account deletion results in the immediate deletion of all stored data associated with your account from our active systems, including transcripts, meeting notes, summaries, and reports. Such data will be automatically and permanently purged from our encrypted backups within our standard backup cycle (up to 30 days), except to the minimum extent required by applicable law.
• We retain your profile information, credentials, and user data for as long as you have an account with us.
• We retain your payment data for as long as we need to process your purchase or subscription.
• We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

Personal Data of Children

As noted in our Terms, we do not knowingly collect or solicit Personal Data from children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at support@trysmooth.ai.

U.S. State Law Privacy Rights

Residents of certain U.S. states, including California (under the CCPA/CPRA), Colorado, Connecticut, Utah, and Virginia, may have specific rights regarding their Personal Data.

Depending on your state of residence, your rights may include:

• Right to Know and Access: The right to request information about the categories and specific pieces of Personal Data we have collected about you, the sources of that data, and our business purposes for collecting it.
• Right to Delete: The right to request the deletion of your Personal Data, subject to certain exceptions.
• Right to Correct: The right to request the correction of inaccurate Personal Data that we maintain about you.
• Right to Opt-Out of Sale or Sharing: The right to direct us not to sell or share your Personal Data for targeted advertising purposes. Smooth AI does not "sell" your Personal Data as defined under these laws.
• Right to Limit Use of Sensitive Personal Information: The right to limit our use of your sensitive personal data to that which is strictly necessary to perform the Services.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.

To exercise any of these rights, please email us at support@trysmooth.ai with the subject line "State Privacy Rights Request." We may need to verify your identity before processing your request.

European Union, United Kingdom, and Swiss Data Subject Rights

If you are a resident of the European Union ("EU"), United Kingdom ("UK"), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the "GDPR") with respect to your Personal Data, as outlined below.

For this section, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used to individually identify a person, and "processing" generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Smooth AI will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at support@trysmooth.ai.

Personal Data Use and Processing Grounds

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below.

Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at support@trysmooth.ai with the subject line: "GDPR Request: [nature of request]".

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please note that due to the nature of our Services, transcripts cannot be modified after creation. However, you can modify summaries and meeting notes generated from transcripts.
• Erasure:
  • Deleting Your Smooth AI Account: To delete your account, open the Smooth AI web interface, navigate to Settings → Profile → Delete Account. Upon account deletion, all stored data associated with your account will be deleted immediately from active systems, and permanently purged from our encrypted backups within our standard backup cycle (up to 30 days).
  • Deleting Specific Content: You can delete individual transcripts, meeting notes, or summaries from your dashboard at any time.
  • Deleting Other Account-Related Information: You can delete certain other account-related information within your account Settings.
  • For any other questions or requests to delete your Personal Data, please email support@trysmooth.ai.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Smooth AI's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available at edpb.europa.eu.

Transfers of Personal Data

Our Services are hosted and operated through Smooth AI and its Service Providers. Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. By using our Services, you acknowledge that your Personal Data may be transferred, stored and processed in countries where Smooth AI and its Service Providers operate. In some circumstances, your Personal Data may be transferred pursuant to a data processing agreement incorporating standard data protection clauses as required by applicable law.