We collect several different types of information for various purposes to provide and improve our Service to you.

We may create aggregated, de-identified or anonymized data from the personal data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Delyn services and promote our business, provided that we will not disclose such data in a manner that could identify you.

Types of Data Collected

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Contact Data includes name, role at business, email address, phone number.

• Financial Data includes billing information, bank card details.

• Correspondence Data includes email correspondence, notes of conversations where these express an opinion.

• Usage Data includes information about how you use our website or services.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or our services.

• Calendar Data includes event titles, dates, times, participants, and meeting information.

• Recording Data includes audio recordings, transcriptions, conversation participants, dates, times, and content which may contain personal data of third parties.

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Usage Data

When you access the Service with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data ("Usage Data").

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.

• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

• Security Cookies. We use Security Cookies for security purposes.

How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions: We collect the majority of your data through our Delyn products and services on our website, by email, over the phone, in person at meetings or otherwise.

• Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

• Third parties or publicly available sources: We may receive Technical Data about you from analytics providers such as Google with servers based outside of Europe.

Use of Data

REPIO SAS uses the collected data for various purposes:

• To provide and maintain our Service

• To notify you about changes to our Service

• To allow you to participate in interactive features of our Service when you choose to do so

• To provide customer support

• To gather analysis or valuable information so that we can improve our Service

• To monitor the usage of our Service

• To detect, prevent and address technical issues

• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• In anticipation of or in accordance with the terms of use or service agreement that we have with you

• Where it is necessary for our legitimate interests (or those of a third party) in the operation of our business and we have made an objective assessment that your interests and fundamental rights do not override those interests

• Where we need to comply with a legal or regulatory obligation

Data Shared with Third-Party AI Models

Data Shared with AI Models

In order to provide transcription, categorization, analysis, and draft reply functionalities, our service employs machine learning models using third party AI models. We require our AI service providers to use your information only for the purpose of providing our Service. We do not allow those providers to train their AI models using your data.

The following data types may be shared with these AI models:

• Email Content and Data: Subject lines, email body text, sender and recipient information.

• Calendar Data: Event titles, dates, and times.

• Audio Recording Data: conversation participants, dates, times, the content of audio recordings generated by Users which may contain personal data, including personal information of third parties. Before providing Delyn with Audio Recording Data please confirm you have secured the necessary permissions or consents from those third parties before sharing such personal data with Delyn.

• Chat Data: Messages, conversation history, and related metadata for AI-powered assistance features.

This data is processed for the sole purpose of delivering the services described and is not used for any other functions within the AI models.

User Consent for Data Sharing with AI Models

Before sharing any of your data with our AI models, we seek explicit user consent. Upon initial setup or significant changes to this privacy policy, a prompt will appear within the app requiring users to consent to data sharing for AI processing.

Third Party Data Retention

We have Zero Data Retention agreements with our AI service providers in which our providers do not store customer API data on their servers.

Use of Google User Data

The use of raw or derived user data received from Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements. We are not using the data to train AI/ML models.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), REPIO SAS legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

REPIO SAS may process your Personal Data because:

• We need to perform a contract with you

• You have given us permission to do so

• The processing is in our legitimate interests and it is not overridden by your rights

• For payment processing purposes

• To comply with the law

Retention of Data

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting 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 whether we can achieve those purposes through other means, and the applicable legal requirements.

REPIO SAS will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

REPIO SAS will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

In some circumstances, you can ask us to delete your data. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Transfer of Data

Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside France and choose to provide information to us, please note that we transfer the data, including Personal Data, to France and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

REPIO SAS will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

International Transfers

A number of our service providers processing your personal data on our behalf are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that either:

• We have a specific contract with that processor in a form approved by the European Commission which ensures that service provider gives your personal data the same protection it has in Europe; or

• If the provider is based in countries with adequacy decisions by the European Commission; or

• Other appropriate safeguards as recognized by applicable data protection laws.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Disclosure of Data

We will need to share your personal data with the parties set out below:

• Our service providers acting as processors who may be based outside the EEA and who provide us with account management, IT support, IT backup, data storage, email management, system administration, and AI/language model services.

• Analytics and advertising service providers which may have servers based outside the EEA for the purpose of analyzing user behavior.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Business Transaction

If REPIO SAS is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, REPIO SAS may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

REPIO SAS may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation

• To protect and defend the rights or property of REPIO SAS

• To prevent or investigate possible wrongdoing in connection with the Service

• To protect the personal safety of users of the Service or the public

• To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. REPIO SAS aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you.Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object. You have the right to object to our processing of your Personal Data.

• The right of restriction. You have the right to request that we restrict the processing of your personal information.

• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where REPIO SAS relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• Stripe

  Their Privacy Policy can be viewed at https://stripe.com/en-fr/privacy

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.