Privacy Policy

At Hedy AI, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Hedy AI’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

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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.

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Personal Data

​AI-Specific Data Processing

Understanding How Hedy Uses Artificial Intelligence

Hedy leverages advanced artificial intelligence to provide real-time conversation insights while maintaining the highest standards of user privacy and data protection. Here are our AI processing principles:

1. Local-First Processing

1. Audio capture and transcription occur directly on your device
2. No audio data is transmitted to external servers

2. Contextual Analysis
Our AI provides insights by:

• Analyzing conversation context
• Generating relevant suggestions
• Creating summaries and highlights
• Identifying key themes and action items

3. AI Service Provider Relationship‍

• Conversations are analyzed using Anthropic's Claude AI or Google Cloud Platform Vertex AI (“AI Vendors”)
• AI Vendors process transcripts solely for the purpose of generating Hedy insights
• No conversation data is retained or used for model training
• Strict data handling protocols prevent misuse or unauthorized access

4. User Data Control‍

• Users can delete session data at any time
• No permanent storage of conversation details without explicit user consent
• Granular privacy settings allow users to control data retention

Consent and Transparency
By using Hedy, you understand and consent to this privacy-preserving AI analysis approach. We are committed to continuous improvement of our privacy protections while delivering intelligent, context-aware conversation support.

Data Processing Limitations‍

• AI analysis does not create persistent user profiles
• No individual user conversations are used to improve AI models

Ongoing Privacy Commitment
We continuously review and enhance our AI processing methods to protect user privacy while delivering innovative conversational insights.

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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:

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Google API Data

Notwithstanding the foregoing, to the extent we collect Personal Data about you through use of a Google API, our use and transfer of such Personal Data to any other third-party will be in compliance with the Google API Services User Data Policy, including the Limited Use Requirements.

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Experimental Features and Pre-GA Offerings

Hedy AI may offer features labeled as "Experimental" or similar designations ("Experimental Features"). These features operate under different terms regarding data processing and privacy than our standard services.

Data Processing for Experimental Features

When using Experimental Features:

1. Modified Data Handling: Your Personal Data may be processed differently from our standard services, including:

• Alternative AI models and processing methods
• Additional third-party service providers
• Different data retention periods and protection protocols

2. Third-Party Services: Experimental Features may use third-party services (such as experimental AI models) where:

• Standard data processing agreements may not apply
• Data location restrictions may vary
• Service level agreements may be limited

3. Limited Warranties: Experimental Features are provided "AS IS" and may be changed or discontinued without notice. Standard service level agreements and data protection guarantees may not apply.

Your Responsibilities and Rights

Before using Experimental Features:

• Review any feature-specific privacy notices
• Consider if the experimental nature suits your use case
• Exercise caution with sensitive data

Your data subject rights continue to apply but may be implemented differently for Experimental Features.

Changes and Termination

We will clearly identify Experimental Features and provide specific privacy notices when applicable. We reserve the right to modify, discontinue, or terminate access to any Experimental Feature at any time.

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Categories of Sources of Personal Data

• You
  • When you provide such information directly to us.
    • When you create an account or use our interactive tools and Services.
    • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
    • When you send us an email or otherwise contact us.
  • When you use the Services and such information is collected automatically.
    • Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
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    • If you use a location-enabled browser, we may receive information about your location.
    • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
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• Third Parties
  • Vendors
    • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
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    • We may use vendors to obtain information to generate leads and create user profiles.
  • Third Party Accounts
    • If you sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

Our Commercial or Business Purposes for Collecting or Disclosing Personal Data

• Providing, Customizing and Improving the Services
  • Creating and managing your account or other user profiles.
  • Processing orders or other transactions; billing.
  • Providing you with the products, services or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Improving the Services, including testing, research, internal analytics and product development.
  • Personalizing the Services, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”).
• Marketing the Services
  • Marketing and selling the Services.
• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Hedy AI or the Services.
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  • Sending emails and other communications according to your preferences or that display content that we think will interest you.
• Meeting Legal Requirements and Enforcing Legal Terms
  • 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.
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  • Protecting the rights, property or safety of you, Hedy AI or another party.
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  • Enforcing any agreements with you.
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  • Responding to claims that any posting or other content violates third-party rights.
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  • Resolving disputes.

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.

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How We Disclose Your Personal Data

We may disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
  • Product fulfillment and delivery providers.
  • Payment processors.
• Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
  • Companies that track how users found or were referred to the Services.
  • Companies that track how users interact with the Services.
• Parties You Authorize, Access or Authenticate
  • Organizations through which you access our Services (such as your employer)
    Third parties you access through the services.
  • Social media services.
  • Other users.

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Data Sales Prohibition

Hedy AI does not sell, lease, rent, or trade your Personal Data to any third parties. We may share data with service providers as described in this policy, but we do not engage in the sale of personal information for commercial purposes.

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Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

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Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Tracking Tools and Opt-Out

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 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.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings in your browser settings. 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.

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Data 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. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; 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.

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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 who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal 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:

• We retain your profile information, credentials, and User Data for as long as you have an account with us.
• We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

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Personal Data of Children

As noted in the Terms of Use, 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 (at) hedy.bot.

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Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents have the right to: 

• Request access to the personal data we collect about you 
• Request deletion of your personal data 
• Be informed about how your data is used 

In order to submit such a request, please contact us at support@hedy.bot.

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Nevada Resident Rights

If you are a resident of Nevada, you have the right to: 

1. The ability to access your personal data 
2. Options to request data deletion 
3. Transparency about data processing practices

You can exercise this right by contacting us at support@hedy.bot with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

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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. Hedy 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@hedy.bot.

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Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

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Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

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.

• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.some text
  • Profile or Contact Data
  • Recordings
  • Other Identifying Information that You Voluntarily Choose to Provide
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:some text
  • Profile or Contact Data
  • Payment Data
  • Device/IP Data
  • Web Analytics
  • Other Identifying Information that You Voluntarily Choose to Provide
  • We may also de-identify or anonymize Personal Data to further our legitimate interests. 
  • Examples of these legitimate interests include (as described in more detail above):
  • Providing, customizing and improving the Services.
  • Marketing the Services.
  • Corresponding with you.
  • Meeting legal requirements and enforcing legal terms.
  • Completing corporate transactions.
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

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Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

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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@hedy.bot with the subject line: “GDPR Request: [nature of request]”.

Your request must include enough information for us to verify your identity, relationship with Hedy AI, and the nature of your request. In some circumstances, we may not be able to fully comply with your request, such as if we are unable to verify your identity, your request it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision.

Lastly, please note that where we process your Personal Data as a data processor on behalf of another organization, you may need to submit your request directly to that organization.

• 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 of transcripts.
• Erasure: You can delete certain account-related information within your account settings. You can request that we erase other Personal Data from our systems.
• 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 Hedy 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 here.

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Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Hedy AI and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Hedy AI in the U.S. and will be hosted on U.S. servers, and you authorize Hedy AI to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.

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Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• hedy.bot
• support@hedy.bot
• Hedy AI, 5331 S Macadam Ave, Ste 258 PMB 1137, Portland, OR 97239-3871
  

If you are in the European Union/EEA, you may address privacy-related inquiries to our EU representative pursuant to Article 27 GDPR:

• EU-REP.Global GmbH
• hedy@eu-rep.global
• Hopfenstraße 1d, 24114 Kiel, Germany

You can contact our EU representative directly for matters related to the processing of your Personal Data.

If you are in the United Kingdom, you may address privacy-related inquiries to our UK representative pursuant to Article 27 GDPR:

• DP Data Protection Services UK Ltd.
• hedy@eu-rep.global
• 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom