đź”’ Privacy Policy
Last Updated: Oct 6, 2024
1. Introduction
‍This Privacy Policy describes how Wispr AI, Inc. ("Wispr" or "Company") collects, uses, and handles your personal data ("Personal Data"), and what choices you have when you use our website, applications, platforms, and services (collectively, the "Services"). By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree to the practices described in this Privacy Policy, please do not access or use the Services. Any capitalized terms not defined herein have the meaning ascribed to them in our Terms of Service.
2. Definitions
“Data Controller” means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, Wispr is a Data Controller of your data.
“Data Processor” means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Data Processors in order to process your data more effectively.‍
3. Information We Collect
We collect several different types of information for various purposes to provide and improve our Services, including Personal Data and Usage Data as set forth below. Â
A. Personal Data
While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personal Data may include without limitation:
- Email address
- First name and last name
- Phone number
- Cookies
- Usage Data (as defined below)
- Any other Personal Data that you voluntarily provide to Wispr.
B. Usage Data
We may collect information that your browser sends whenever you visit our Services or when you access Services by or through a mobile device, including without limitation your Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data (“Usage Data”). When you access the Services with a mobile device, this Usage Data may include information such as 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.
C. Audio Recordings
By default, your audio recordings are not saved on our servers & are not accessible to anyone but you. If you chose to share your data with us, we collect any audio recordings of your voice, and those recordings may include Personal Data that you choose to include (for example, if you say your name in a voice recording).
D. Text Inputs
By default, text generated from the Outputs are not saved on our servers & are not accessible to anyone but you. If you chose to share your data with us, we may collect text and other content you share to provide context for the Services to generate Outputs. Such text and other content may include Personal Data that you choose to share.
E. Third-Party Platforms
We may collect information when you connect to your account using an account maintained by a third party, such as a social media account (“Third-Party Account”). The Services may collect information about you from your Third-Party Accounts in accordance with your permissions. When you connect to us through a Third-Party Account like Facebook or Google, we receive information from that third party identifying your account. We collect and store this information and use it to help you connect to the Services. Connecting your account to a Third-Party Account is completely optional, and you will have the opportunity to grant permission when you attempt to connect. You can revoke permission by logging into the Third-Party Account and disconnecting Wispr from there, and through the native applications on your smartphone. We may retain the information we collected previously from you.
F. Artificial Intelligence Platform Data
As part of the Services, Wispr may provide an artificial intelligence (AI) platform or service to Customers. For the purposes of this policy, “Customer” means an entity that has executed an agreement with Wispr for the Services. If you are an individual using Wispr’s services as a result of our relationship with Customer (such individuals, “End User(s)”), please note that the Customer is responsible for obtaining the necessary consents from End Users and complying with applicable laws or regulations.
G. Payment Information
When you sign up for any of our Paid Services, our third-party payment processor, Stripe, Inc. (“Stripe”), collects and processes your payment-related information, such as your name, email, billing address, credit/debit card or banking information, or other financial information. Stripe’s privacy policy is available here.‍
4. Use of Data
‍Wispr may use Personal Data and Usage for various purposes:
- Service Operation. To provide, update, maintain, improve, monitor, and protect our Services, including without limitation use of Customer Content to train our LLMs and other AI models. For additional information about how we use Customer Content for model training, please see our Data Usage Policy.
- Communication. To provide customer and technical support, to send service-related emails, and to send marketing emails about new product features or other news about Wispr.
- Digital Advertising. To display digital advertising to you on our website or other websites (including through the use of cookies or other technologies).
- Administration. For transactional, billing, account management, tax, and administrative matters.
- Compliance. To comply with applicable laws and regulations or a court or other legal order.
- Risk Mitigation. To detect violations of our legal terms, enforce the legal terms that govern your use of the Services, or to detect, prevent, and respond to potential fraud or misuse of the Services.
- Interaction Improvement. To develop and improve our marketing activities to better match your interests and preferences.
- Marketing. To contact you with 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 any unsubscribe link or other mechanism provided to remove yourself from such communications.
- Other. For other lawful purposes with your consent.
Our lawful basis to collect and use your Personal Data and Usage Data will depend on the type of information and the context in which we process it. We may process your information to enter into or perform a contract with you, for the purposes of our legitimate interests (unless your rights and freedoms override those interests), with your consent, or to comply with our legal obligations (e.g. to comply with applicable laws and regulations or a court or other legal order).‍
5. Use of Cookies and Other Tracking Technologies
Wispr, and the third parties we work with, use cookies and other tracking technologies on the Services to collect information about your usage of the Services and your device. Our use of such technologies is described in our Cookie Policy.‍
6. Online Analytics and Tailored Advertising
A. Analytics
We may use third-party web analytics services on the Services, such as those of Google Analytics. These vendors use the sort of technology described in the “Information Collection and Use” section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by such technology will be disclosed to or collected directly by these vendors, who use the information to evaluate your use of the Services. We also may use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for web analytics, you may install the Google Analytics Opt-Out Browser Add-on.
B. Tailored Advertising
Though we do not engage in advertising as of the date of this Privacy Policy, we may in the future allow third-party advertising networks to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our website and other online services and (b) report how our marketing content impressions and interactions with these marketing impressions are related to visits to our online services. We may also allow other unaffiliated parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may disclose to a vendor in hashed, non-human-readable form.If you are interested in more information about tailored advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative's (“NAI”) Consumer Opt-Out Link, the Digital Advertising Alliance's (“DAA”) Consumer Opt-Out Link, and/or the European Interactive Digital Advertising Alliance to opt-out of receiving tailored advertising from companies that participate in those programs. To exercise choices about how Google personalizes Display Advertising or to customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content may not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit these opt-out pages, or you subsequently erase your cookies, or use a different computer or change web browsers, your opt-out may no longer be effective.‍
7. Retention of Data
We 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. We retain your Personal Data for different periods of time depending on what it is, how we use it, and how you configure your settings. We will either delete or anonymize Personal Data once it is no longer needed or after expiration of the applicable retention periods. If we anonymize, aggregate, or de-identify Personal Data, we may use and disclose it for any business purpose. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. ‍
8. 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 the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Wispr will take 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 organization or a country unless there are adequate controls in place including the security of your data and other personal information.‍
9. Sharing With Others
This section describes when we may disclose Personal Data:
- Services Providers. We may disclose Personal Data with Services Providers who are working on our behalf (e.g. billing and payment service providers, analytics providers, cloud providers, communications providers).
- Customers. If a customer of Wispr (e.g. your employer) has given you access to the Services, we may disclose certain information about you (e.g. your account or device information) with that Customer to satisfy our contractual obligations and for the purposes otherwise described herein.
- Protection of Wispr and Others. We may disclose your information to protect the rights, property, or personal safety of Wispr, its agents and affiliates, its users, and the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes. We may also disclose your Personal Data if we believe that disclosure is reasonably necessary to comply with any applicable law or regulation, if we are required by law to comply with any court order or legal process or respond to any government or regulatory request, and to maintain and enforce our agreements and policies.
- Business Transfers. We may disclose your Personal Data in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, in reliance on our legitimate business interests.
- Affiliates. We may disclose Personal Data with our affiliates who use Personal Data as set out in this Privacy Policy.
- Advertising Partners. We may partner with third party advertising networks, exchanges, and social media platforms (e.g. LinkedIn) to display advertising on our Services or to manage and service advertising on other sites, and we may disclose or otherwise make available Personal Data with them for this purpose. Please see our Cookie Policy for more information.
- Others with Your Consent. We may share your Personal Data with other third parties with your express consent.‍
10. How We Secure Your Information
‍The security of your data is important to us. We implement technical, administrative and physical safeguards to protect the information we collect from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, 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.‍
11. Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. You can learn more about GDPR here. We aim 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 what Personal Data we hold about you and if you want it to be removed from our systems, please email us at [email protected].
In certain circumstances, you have the following data protection rights to:
- access, update or to delete the information we have on you;
- have your information rectified if that information is inaccurate or incomplete;
- object to our processing of your Personal Data;
- request that we restrict the processing of your personal information;
- be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
- withdraw your consent at any time where we rely on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Services without some necessary data.
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).‍
12. Children’s Personal Data
To use the Services, you must be at least 13 if you reside in the United States, and 16 if you reside anywhere else. If you are under the age of 18, depending on where you live, you may need to have your parent or guardian’s consent to these Terms and they may need to enter into these Terms on your behalf. If you are a parent or guardian and become aware that your child provided us with Personal Data, you should contact us at [email protected].‍
13. Services Providers
We may use third-party companies, vendors, personnel and other service providers to facilitate our Services, provide Services on our behalf, analyze how our Services are used, and provide similar third-party services (collectively, "Services Providers"). These Services Providers may 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.‍
14. Links to Third-Party Websites
The Services may contain links to third-party websites or services. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information by third parties will be subject to the privacy policies of the third-party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third parties before providing information to them.‍
15. Changes to This Privacy Policy
We’ll update this Privacy Policy from time to time. When we make changes, we’ll update the date at the top of the Privacy Policy. If we make material changes to this Privacy Policy, we’ll notify you before they take effect by prominently posting a notice of the changes on our Services, sending you an email, or providing another reasonable method of notice. We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit. This will help ensure you better understand your relationship with us, including the ways we process your Personal Data.‍
16. Contact Us
If you have any questions about this Privacy Policy, please contact us by email at [email protected].‍
17. Privacy Notice for California Residents
If you are a California resident, please review this supplemental notice.