Privacy Policy

Last updated: 09/13/2024

PRIVACY NOTICE

This privacy notice for Minutes AI, a product of SLAM Ventures, LLC ("Company," "we," "us," or "our"), outlines how we collect, store, use, and/or share ("process") your information when you use our services ("Services"). This includes when you:

We encourage you to read this privacy notice carefully to understand your privacy rights and choices. If you disagree with our policies and practices, please refrain from using our Services. For any questions or concerns, please contact us at info@myminutes.ai.

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. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
  6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  7. HOW LONG DO WE KEEP YOUR INFORMATION?
  8. HOW DO WE KEEP YOUR INFORMATION SAFE?
  9. WHAT ARE YOUR PRIVACY RIGHTS?
  10. CONTROLS FOR DO-NOT-TRACK FEATURES
  11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  12. DO WE MAKE UPDATES TO THIS NOTICE?
  13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

In Short: We collect personal information you provide, data from your device and app usage, and information about recordings you create or upload.

Personal Information You Provide

When you use our Services, you may voluntarily provide us with certain personal information, including:

We do not collect or process sensitive information.

Information Automatically Collected

When you use our Services, we automatically collect certain information, including:

  1. Device Data:

    • Device type (e.g., smartphone, tablet)
    • Operating system and version
    • Unique device identifiers
    • IP address
    • Browser type and version (if applicable)
  2. App Usage Data:

    • Features and screens you interact with
    • Time and duration of app usage
    • App performance metrics
  3. Log Data:

    • Non-identifying crash logs and error reports
    • Diagnostic information for troubleshooting
  4. Location Data:

    • Approximate location (based on IP address or coarse location if permitted)

Note: You can control location permissions through your device settings.

Recording and Audio File Information

When you create a recording or upload an audio file:

How We Use This Information

We use the collected information to:

We are committed to using your information responsibly and in accordance with this privacy policy. You have control over certain data collection practices, and we provide options to manage your information as detailed in later sections of this policy.

Children's Privacy

Our App is not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected such information, we will take steps to delete it.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide our core services, improve our product, ensure security, and comply with legal obligations. This includes generating transcriptions and summaries from your audio recordings.

We process your personal information for various purposes, depending on how you interact with our Services:

  1. Core Services:

    • Transcription and Summary Generation: We process the audio recordings you provide to create accurate transcriptions and insightful summaries, which are the primary services we offer.
    • Account Management: We use your information to create and maintain your account, allowing you to access our Services seamlessly.
  2. Product Improvement:

    • Service Enhancement: We analyze usage patterns and feedback to improve our transcription algorithms and summary generation capabilities.
    • User Experience Optimization: We use data to enhance the app's interface and functionality based on how users interact with our Services.
  3. Communication:

    • User Support: We may use your information to respond to your inquiries, provide customer support, and send important service-related notifications.
    • Updates and Marketing: With your consent, we may send you product updates, newsletters, or marketing communications.
  4. Security Prevention:

    • Account Protection: We implement security measures to safeguard your account and personal information.
  5. Legal Compliance:

    • Regulatory Requirements: We process information as required by applicable laws, regulations, or legal processes.
    • Enforcing Our Terms: We may use your information to enforce our terms of service and protect our legal rights.
  6. Vital Interests:

    • Safety Measures: In extraordinary circumstances, we may process your information if necessary to protect an individual's vital interests or public safety.
  7. With Your Consent:

    • Additional Processing: We may process your information for other purposes not listed here, but only with your explicit consent.

We are committed to processing your information responsibly and transparently. You have control over certain aspects of how we use your data, and we provide options to manage your preferences within our Services.

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

In Short: We process your personal information only when we have a valid legal reason to do so, which varies depending on your location and the specific circumstances.

As a global service, we comply with various data protection laws worldwide. The legal bases we rely on to process your information may differ based on your location and the specific purpose of the processing. Here's an overview of the main legal bases we use:

For Users in the European Union (EU) and United Kingdom (UK):

Under the General Data Protection Regulation (GDPR) and UK GDPR, we may process your personal information based on:

  1. Consent: When you've explicitly agreed to the use of your information for a specific purpose. You can withdraw this consent at any time.

  2. Performance of a Contract: When processing is necessary to fulfill our contractual obligations to you or to take steps at your request before entering into a contract.

  3. Legal Obligations: When we need to comply with a legal or regulatory obligation.

  4. Legitimate Interests: When processing is necessary for our legitimate interests or those of a third party, except where such interests are overridden by your fundamental rights and freedoms.

  5. Vital Interests: In rare cases, when processing is necessary to protect someone's life or safety.

For Users in Canada:

We process your information based on:

  1. Express Consent: When you've explicitly agreed to the use of your information for a specific purpose.

  2. Implied Consent: In situations where your permission can be reasonably inferred from your actions or inaction.

  3. Legal Exceptions: In some cases, Canadian law allows us to process your information without consent, such as:

    • For fraud prevention and investigation
    • For legal proceedings or law enforcement purposes
    • In emergency situations to protect an individual's safety

For Users in the United States and Other Regions:

We process your information in accordance with applicable local laws and based on:

  1. Consent: When you've agreed to the processing of your information.

  2. Contractual Necessity: When processing is required to provide our services to you.

  3. Legal Compliance: When we need to comply with applicable laws and regulations.

  4. Legitimate Business Purposes: When processing is necessary for our legitimate business interests, balanced against your rights and interests.

Global Considerations:

Regardless of your location, we are committed to processing your information responsibly and transparently. We always strive to:

  1. Collect and use your information fairly and lawfully.
  2. Process your information only for specified, explicit, and legitimate purposes.
  3. Limit our collection and processing to what is necessary for the purposes for which it is processed.
  4. Keep your information accurate and up to date.
  5. Retain your information only for as long as necessary.
  6. Ensure appropriate security measures to protect your information.

You have the right to object to our processing of your personal information or to request that we delete or restrict the processing of your information. To exercise these rights, please contact us using the information provided in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section.

We regularly review our privacy practices to ensure compliance with evolving global privacy laws and standards. For the most current information on how we process your data, please refer to this privacy policy, which we update periodically.

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

In Short: We share your information with select third-party service providers to facilitate our Services, and may share information in specific business situations.

We may share your personal information in the following situations:

  1. Third-Party Service Providers: We share data with trusted partners to help perform essential business operations and provide our Services. These include:

    • Firebase: For data storage, authentication, and database services (Firestore)
    • Groq API and Deepgram: For audio transcription services
    • OpenAI: For generating summaries and powering chat features
    • PostHog: For analytics and usage data collection
    • RevenueCat: For managing in-app purchases and subscriptions
    • AppsFlyer: For marketing analytics and attribution
    • Apple: As an iOS app, some data may be shared with Apple in accordance with their policies
    • Vercel: For hosting and serving our web application and server
  2. 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.

  3. With Your Consent: We may disclose your personal information for any other purpose with your consent.

  4. Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena.

  5. Vital Interests and Legal Rights: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

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.

5. OUR STANCE ON THIRD-PARTY WEBSITES AND SERVICES

In Short: We are not responsible for the privacy practices or content of third-party websites, services, or applications that may be linked to or advertised on our Services.

Third-Party Links and Advertisements

Our Services may contain:

These third-party entities may have their own links to other websites, services, or applications.

Our Responsibility and Liability

We want to make it clear that:

  1. We do not endorse or guarantee any third-party websites, services, or applications.
  2. We are not liable for any loss or damage resulting from your use of third-party websites, services, or applications.
  3. The inclusion of a link or advertisement does not imply our endorsement of that third party.

Data Safety and Privacy

Regarding your data and privacy:

User Responsibility

As a user of our Services, you should:

  1. Be aware of the risks when accessing third-party content or providing information to third parties.
  2. Review the privacy policies and terms of service of any third-party websites, services, or applications you access through our Services.
  3. Contact third parties directly with any questions about their privacy practices or policies.

Our Recommendation

We strongly recommend that you exercise caution and inform yourself about the privacy practices of any third-party website, service, or application before sharing your personal information or engaging with their content.

By understanding and following these guidelines, you can better protect your privacy and make informed decisions when interacting with third-party content through our Services.

6. INTERNATIONAL DATA TRANSFERS AND STORAGE

In Short: We operate globally and may transfer, store, and process your information in various countries worldwide.

Global Operations and Data Storage

Our services are provided through a global network of servers and partners. While our primary servers are located in the United States, we may transfer, store, and process your information in facilities around the world, including but not limited to:

This global approach allows us to provide efficient and reliable services to our users worldwide.

Data Protection for International Transfers

We understand that data protection laws vary by country. When transferring data internationally, we implement robust safeguards to ensure your information is protected, regardless of its location. These safeguards include:

  1. European Commission's Standard Contractual Clauses (SCCs):

    • We use SCCs for transfers of personal data from the EEA, UK, and Switzerland to countries without an adequacy decision.
    • These legally binding clauses ensure that all recipients protect personal data in accordance with EU data protection standards.
  2. Binding Corporate Rules (BCRs):

    • Our BCRs have been approved by EEA and UK data protection authorities.
    • They provide a consistent set of rules for international data transfers within our corporate group.
    • You can find a copy of our BCRs at: [Insert link to BCRs]
  3. Data Transfer Impact Assessments:

    • We regularly assess the privacy laws and practices of countries where we transfer data.
    • If a country's protections are deemed inadequate, we implement additional safeguards.
  4. Encryption and Security Measures:

    • All international data transfers are protected with industry-standard encryption.
    • We employ strict access controls and security protocols across our global infrastructure.

Your Rights Regarding International Transfers

Regardless of your location, you have the right to:

To exercise these rights or for more information, please contact us at info@myminutes.ai.

Compliance with Local Laws

We strive to comply with data protection and privacy laws in all jurisdictions where we operate. This includes, but is not limited to:

If you're concerned about how your data is handled in your specific country, please contact us for more detailed information.

Continuous Improvement

We regularly review and update our international data transfer practices to ensure ongoing compliance with evolving global privacy standards and regulations.

By using our Services, you acknowledge and consent to the international transfer and processing of your information as described in this section. If you have any questions or concerns about international data transfers, please don't hesitate to contact us.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We retain your information only as long as necessary, and you have control over the deletion of your data.

Data Retention Period

We keep your personal information only for as long as it's needed to:

We don't keep your personal information any longer than the period you have an active account with us, unless required by law.

Your Control Over Your Data

You have significant control over your data:

  1. Document Deletion: You can delete your documents at any time. Once deleted, they are permanently removed from our systems.

  2. Account Deletion: You can delete your entire account whenever you choose. This action permanently removes all your personal information and content from our services.

When We Delete Your Data

We will delete or anonymize your personal information when:

Data in Backups

In some cases, your information may be stored in backup archives. If this is the case:

Legal Requirements

In some instances, we may be legally required to retain certain information for specific periods. In such cases, we will comply with the law while ensuring the security and confidentiality of your data.

Commitment to Data Minimization

We are committed to keeping your personal information only for as long as necessary. We regularly review our data retention practices to ensure we're not keeping data longer than needed.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We employ a multi-layered approach to protect your personal information using industry-standard security measures and best practices.

At Minutes AI, we take the security of your personal information seriously. We have implemented a comprehensive system of technical and organizational measures to protect your data. Here's an overview of our security practices:

  1. Encryption and Secure Transmission:

    • All data transmitted to and from our services is encrypted using industry-standard SSL/TLS protocols.
    • We use end-to-end encryption for sensitive data to ensure it remains protected throughout its lifecycle.
  2. Secure Infrastructure:

    • We utilize Firebase, a Google Cloud platform, which adheres to rigorous security standards including SOC 2 and ISO 27001 certifications.
    • Our systems are regularly updated and patched to address potential vulnerabilities.
  3. Access Controls:

    • We implement strict access controls and authentication mechanisms to ensure only authorized personnel can access user data.
    • Multi-factor authentication is required for all administrative access to our systems.
  4. Data Storage and Backup:

    • Your data is stored in secure, geographically distributed data centers with redundancy to prevent data loss.
    • Regular backups are performed and stored securely to ensure data recovery in case of unforeseen events.
  5. Monitoring and Incident Response:

    • We employ 24/7 monitoring systems to detect and respond to potential security threats.
    • Our incident response team is prepared to act swiftly in case of any security events.
  6. Regular Security Audits:

    • We conduct regular internal and external security audits to identify and address potential vulnerabilities.
    • Third-party penetration testing is performed periodically to evaluate our security posture.
  7. Employee Training:

    • Our team undergoes regular security awareness training to stay updated on the latest security best practices and threats.
  8. Compliance:

    • We adhere to industry standards and regulations related to data protection and privacy.

While we are committed to implementing and maintaining strong security measures, it's important to note that no method of electronic storage or transmission over the Internet is 100% secure. We continuously work to improve our security practices, but we cannot guarantee absolute security.

Your Role in Security:

By using our services, you acknowledge and accept that the transmission of information over the Internet carries inherent risks, and while we strive to protect your personal information, we cannot guarantee its absolute security. If you have any concerns about the security of your information, please contact us immediately at security@myminutes.ai.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your location, you have specific rights regarding your personal information. We respect these rights and provide ways for you to exercise them.

Global Privacy Rights

Regardless of your location, you have the right to:

  1. Access your personal information
  2. Request corrections to your data
  3. Delete your account and personal information
  4. Withdraw consent for data processing (where applicable)
  5. Lodge complaints about our data practices

To exercise these rights, please contact us at info@myminutes.ai.

Regional-Specific Rights

Different regions have additional protections:

European Economic Area (EEA), United Kingdom (UK), and Switzerland

You have the right to:

If you believe we're unlawfully processing your data, you can complain to your local data protection authority:

California, USA

Under the California Consumer Privacy Act (CCPA), you have the right to:

Canada

Under the Personal Information Protection and Electronic Documents Act (PIPEDA), you have the right to:

Australia

Under the Privacy Act 1988, you have the right to:

Other Regions

Many countries have their own data protection laws. We're committed to complying with applicable laws wherever our users are located. If you have questions about your local rights, please contact us.

How to Exercise Your Rights

  1. Account Settings: Log in to your account to review, update, or change your information.
  2. Account Termination: You can request to terminate your account at any time. We will deactivate or delete your account and information from our active databases.
  3. Data Retention: We may retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our terms, or comply with legal requirements.
  4. Withdrawing Consent: If we rely on your consent for processing, you can withdraw it anytime. This won't affect the lawfulness of processing before withdrawal.

Response to Requests

We'll respond to your requests in accordance with applicable data protection laws. In some cases, we may need to verify your identity or request additional information to process your request.

Updates to Privacy Practices

We regularly review and update our privacy practices. Please check this privacy notice periodically for any changes.

If you have any questions or concerns about your privacy rights, please don't hesitate to contact us at info@myminutes.ai.

10. DO-NOT-TRACK, APP TRACKING TRANSPARENCY, AND ANALYTICS

Do-Not-Track (DNT) for Web Browsers

Many web browsers offer a Do-Not-Track (DNT) feature that allows you to signal your preference not to have your online activities tracked. However, there is currently no universal standard for recognizing and implementing DNT signals. As a result, our website does not currently respond to DNT browser settings or signals.

App Tracking Transparency for iOS

For our iOS app users, we adhere to Apple's App Tracking Transparency (ATT) framework. This means:

  1. We will request your permission before tracking your activity across other companies' apps and websites.
  2. You can easily manage your tracking preferences in your iOS device settings.
  3. If you choose to opt-out of tracking, we will respect your decision and limit data collection accordingly.

Analytics and Attribution with AppsFlyer

We use AppsFlyer, a mobile analytics and attribution platform, to help us understand how users interact with our app and the effectiveness of our marketing efforts. AppsFlyer may collect certain data, including:

  1. Device information (e.g., device type, operating system version)
  2. App usage data (e.g., app opens, feature interactions)
  3. Installation attribution data (how you found and installed our app)

AppsFlyer's data collection complies with Apple's App Tracking Transparency requirements. If you opt out of tracking:

For more information about AppsFlyer's privacy practices, please visit their privacy policy at https://www.appsflyer.com/legal/privacy-policy/.

Our Current Practices

User Control and Choices

  1. iOS Settings: You can manage app tracking permissions in your device's Settings > Privacy > Tracking.
  2. In-App Settings: We provide options within our app to manage data collection preferences where applicable.
  3. Contact Us: For any questions or concerns about data collection, please email us at info@myminutes.ai.

Future Changes

If industry standards for tracking preferences change or if we alter our practices:

  1. We will update this privacy notice to reflect those changes.
  2. We may implement new controls or tracking mechanisms as required by law or industry standards.
  3. We will always prioritize user privacy and transparency in our data practices.

For the most up-to-date information on how we handle tracking and privacy in our iOS app, please check for updates to this privacy notice or contact us directly.

11. SPECIFIC PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

In Short: California residents have specific rights regarding their personal information under various state laws.

If you are a California resident, you have special rights concerning your personal information under state laws, including the California Consumer Privacy Act (CCPA) and the "Shine the Light" law.

"Shine the Light" Law

Under California Civil Code Section 1798.83 (known as the "Shine the Light" law), you can request and obtain information about personal data we've shared with third parties for direct marketing purposes within the past year. This request is free and can be made once per year. To make a request, contact us using the information provided at the end of this policy.

California Consumer Privacy Act (CCPA) Rights

Under the CCPA, California residents have the following rights:

  1. Right to Know: You can request information about the personal data we've collected about you in the past 12 months, including:

    • Categories of personal information collected
    • Specific pieces of personal information collected
    • Categories of sources from which we collected personal information
    • Our purpose for collecting or selling personal information
    • Categories of third parties with whom we share personal information
    • Categories of personal information that we sold or disclosed for a business purpose
  2. Right to Delete: You can request that we delete the personal information we have collected from you, subject to certain exceptions.

  3. Right to Opt-Out: You can opt-out of the sale of your personal information. However, we do not currently sell personal information.

  4. Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

Personal Information We Collect

We collect and have collected the following categories of personal information about California residents in the past 12 months:

We collect this information directly from you, from your devices, and from third-party sources. We use and retain this information as needed to provide our services, as detailed earlier in this privacy policy.

How We Use and Share Your Information

We use your personal information for various business purposes described in this privacy notice. We may share your personal information with service providers who process the information on our behalf, subject to contractual protections.

We do not sell your personal information. In the past 12 months, we have not sold any personal information about consumers, including minors under 16 years old.

Exercising Your Rights

To exercise your CCPA rights:

  1. Email us at info@myminutes.ai
  2. Use our contact details at the bottom of this document

Only you or an authorized agent may make a request related to your personal information. We may need to verify your identity before processing your request. We will respond to your request within 45 days, with a possible 45-day extension.

Verification Process

To verify your identity, we may ask you to provide additional information. We will only use this information to confirm your identity. If we cannot verify your identity, we may deny your request.

Additional California Privacy Rights

If you're under 18, reside in California, and have a registered account with us, you can request removal of unwanted data you've publicly posted. Email us with your account email and a statement that you live in California. We'll remove the data from public view, but it may not be completely removed from our systems due to technical constraints.

For questions or concerns about our privacy policies and practices, please contact us using the information provided at the end of this privacy notice.

12. UPDATES TO THIS PRIVACY NOTICE

In Short: We regularly review and update this privacy notice to ensure it accurately reflects our practices and complies with current laws.

Ongoing Updates

We are committed to maintaining transparency about our data practices. As such, we may update this privacy notice periodically to reflect:

How We'll Notify You

When we make updates to this notice, we will:

  1. Revise the "Last Updated" date at the top of this document
  2. Make the updated version immediately effective upon posting

For significant changes that materially alter your rights or our obligations, we may also:

What We Consider Material Changes

Material changes may include, but are not limited to:

Your Responsibility

While we strive to notify you of important changes, we encourage you to:

Continued Use of Our Services

By continuing to use our services after changes to this privacy notice take effect, you agree to be bound by the revised privacy notice. If you disagree with any changes, you should discontinue use of our services and contact us to close your account.

Questions About Updates

If you have any questions or concerns about updates to this privacy notice, please don't hesitate to contact us using the information provided in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

We welcome your questions, comments, and concerns about this privacy notice and our data practices. Here's how you can reach us:

For urgent privacy-related matters, please use the email address above for the fastest response.

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

We respect your right to control your personal information. Depending on your location and applicable laws, you may have the following rights:

  1. Access: Request a copy of the personal information we have about you.
  2. Update: Correct or update your personal information if it's inaccurate or incomplete.
  3. Delete: Request the deletion of your personal information from our systems.
  4. Restrict: Limit how we process your personal information.
  5. Object: Oppose the processing of your personal information for certain purposes.
  6. Data Portability: Request a copy of your data in a structured, commonly used, and machine-readable format.

To exercise these rights:

  1. Account Settings: Log in to your Minutes AI account and use the privacy settings to manage your information.
  2. Email Request: Send a detailed request to privacy@myminutes.ai.
  3. Online Form: Visit our Privacy Request Portal at [Insert link to your privacy request form] to submit a formal request.

Please note:

For more information about your privacy rights or if you're unsatisfied with our response to your request, you have the right to lodge a complaint with your local data protection authority.

We're committed to transparency and will continue to update our practices to protect your privacy rights. Check this privacy notice regularly for any changes in how you can control your personal information.

© SLAM Ventures, LLC.