VOCALZ

PRIVACY POLICY

Last updated: 1 August 2023

	1. WHO ARE WE? Vocalz (the "App") has been developed and is operated by AI VOICE MESSAGING, a French simplified joint stock company located 54, Avenue du Général Leclerc, 92100, Boulogne-Billancourt, France, (hereinafter “AI VOICE MESSAGING”), and/or/with its parent company MWM (together referred as “we” or “us”). In this context and except mentioned otherwise, we are determining the purposes and means of personal data processing (acting as “Data Controller” in accordance with the GDPR or “Business” in accordance with the CCPA). If you have any questions or requests, feel free to contact us by email at support@vocalz.ai. If you wish to contact our data protection officer (DPO) regarding the handling of your personal data and/or to exercise your rights, feel free to contact us at legal@vocalz.ai and detail your request.
	2. WHAT IS THIS DOCUMENT? We are very mindful and committed to respect your private life, the security and the confidentiality of personal data relating to you which is defined by the regulation applicable to you as “Personal Data”. This privacy policy is intended to inform you of how your Personal Data are collected, stored, used and processed by AI VOICE MESSAGING (as Data Controller) and its partners when you use the App and related services (“Services”). This privacy policy applies to all of our Services unless specified otherwise. Please also read Vocalz’ Terms of Use, which describe the terms under which you use and we provide our Services. We undertake to process your Personal Data in accordance with the applicable laws and regulations, including but not limited to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), the California Consumer Privacy Act of 2018 (“CCPA”) (hereinafter the “Applicable Regulations”). Please note that we can amend or update this privacy policy at any time. In such case, you may be informed by a notification as appropriate and/or you can access our privacy policy via the application at any time. We encourage you to regularly check for potential updates. The "last updated" legend at the top of this page indicates when this privacy policy was last revised and the amended version will be effective as of the date it is published.
	3. WHAT PERSONAL DATA ARE COLLECTED, BY WHOM AND WHAT FOR? AI VOICE MESSAGING and/or our partners process your Personal Data in the situations, for the purposes and on the legal grounds set out below (Sections 3.1, 3.2, 3.3). Please note that all of the information detailed below may not always be considered as Personal Data in your jurisdiction. Some types of personal data we collect are required for all Services (for example, your phone number), some types may be required solely for certain features you decide to use (for example, text-to-voice), and some are optional, and subject to your discretion (for example, your photo). We wish to clarify that we do not read or listen to the content of your messages made privately via Vocalz. Unlike other services, we don't use your data for ad targeting or other commercial purposes. AI VOICE MESSAGING only stores the information it needs to function as a secure and feature-rich messaging service. 3.1 Personal Data collected when you download the App Type of Personal Data collected: When you download the App, we might collect the time, date and install source of your download. When you start using our App and Services, the user is anonymously associated with a randomly generated user ID which does not allow identification of the final user (“User ID”). Reasons: To track installs and attribution. Legal Ground for collecting and processing these Personal Data: Our legitimate interests. 3.2 Personal Data collected when you use the App Type of Personal Data collected: We may collect Data limited to: - Your IP address and other information like phone number area codes, to estimate your general location (e.g. country) - Your mobile device identifiers, such as Apple IDFA or Google AAID - which are technical identifiers developed by mobile operating systems which remain under your control and can be reset or erased at any time through your device settings - Basic account data (mobile number, profile name, profile picture) and user choices (including for example whether you have enabled push notifications) - Contacts present in your address book - Technical information about the device you use (including but not limited to hardware model, operating system information, battery level, signal strength, app version, mobile network, mobile operator) and your connection (user agent, type of connection, timestamp); also includes randomly generated authentication tokens, keys, push tokens, and other material that is necessary to transmit messages - Usage information: your activity (including how you use our Services), how you interact with others using our Services, and the time, frequency, and duration of your activities. This also includes information about the features you use; whether you are online; timestamps related to your use such as the times you send and receive messages. - Log and troubleshooting information: how our Services are performing when you use them, like service related diagnostic and performance information; includes log files, timestamps, diagnostic or crash data, error messages or reports - User content: we store messages, voice samples, photos, videos and documents on our servers so that you can access your data from any of your devices anytime without having to rely on third-party backups. All data is stored heavily encrypted and the encryption keys are stored in several other data centres. Reasons: To provide easy-to-use, secure and private messaging services, to better organize and manage the content presented on the App, to run analytics and understand how users interact with our product and services in order to continuously improve them. Legal Ground for collecting and processing these Personal Data: your express consent. 3.3 Personal Data collected when you contact AI VOICE MESSAGING through or in relation to the App Type of Personal Data collected: While you are using the App, you may contact us for various reasons. While doing so, we might collect Personal Data such as your email address, your name, surname, and any other information you include in your messages. Reason: To process and answer your questions and claims. Legal Ground for collecting and processing these Personal Data: Our legitimate interests.
	4. WITH WHOM MAY WE SHARE YOUR PERSONAL DATA OR WHO MAY ACCESS YOUR PERSONAL DATA? The first time you connect on the App, a pop up will be displayed, informing you that if you give your consent, your advertising ID and other data, such as location data, and other demographic and interest data about you will be collected and transmitted to our analytics partners. You are free to refuse or agree to such processing. When you consent to the collection of data for analytics purpose, we may share some of the data listed above with the following categories of recipients: ● Analytics partners: that provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it. Those partners also usually collect data via their own SDK and therefore act as independent controller (and not processor on AI VOICE MESSAGING’s account) with respect to the Personal Data they collect on their own without us sharing any. ● Service providers: account verification, technical, hosting, server, storage, measurement, tracking or client support service providers ● External advisors: We may also need to share your Personal Data with its external advisors (lawyers, accountants, etc.) but such sharing will occur on a need-to-know basis. For further information, please, see our List of Partners Schedule and their own privacy policies. We may update it from time to time, so you understand who we partner with to provide you our Services. 4.1 Other Vocalz Users As part of your Vocalz messaging experience, you share certain information to other users who may be located outside the European Economic Area (“EEA”). You are in control of what you are sending when you send your information to someone you choose to communicate with. Please be mindful that, once you have sent user content to a Vocalz user, they can store or reshare it with others on and off our Services. Those users who have your phone number can see your account information (phone number and optionally profile name and picture if you have chosen to provide some), and can add you to groups and communities where this information is then potentially visible to others in the group or community. When you send a message to another user or to a group, your chosen profile name will become visible to the recipients of the message, including users who do not have you in their contact list. You can report other users by going to Vocalz settings and using the ‘Contact Us’ section. Just as you can do so, other users or third parties may also choose to report to us your interactions and your messages with them or others on our Services; for example, to report possible violations of our Terms or Privacy Policy. When a report is submitted to us, we receive information from the reporter on both the reporting user and those reported. We may ban accounts, temporarily or permanently, if we believe the account activity is in violation of our Terms. 4.2 Group Companies To provide, improve and support our Services, we may share the data we collect about you with affiliated corporate entities, including our parent company, MWM, and its subsidiaries, for the following purposes: ● Certain types of data, such as name, phone number, unique ID, may be disclosed in order to provide joint content and our Services (e.g. registration, analytics, customer support); ● Additionally, we may share certain types of data about you as may be necessary to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; ● We share data with our parent company and affiliated entities due to our global operations as we have different teams, and each such entity (parent or affiliate) may operate the services or other functions (such as development, marketing, etc.). 4.3 Legal and law enforcement Subject to our strict data security and privacy practices and without compromising our encryption, we may disclose certain types of your data, including, and depending on the circumstances, activity data, identifiers and your phone address book, to law enforcement, governmental agencies, or authorised third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other Vocalz user to legal liability, and solely to the extent needed to comply with such purpose. 4.4 Voice-to-Text & Text-to-Voice Transcriptions While using Vocalz, users can choose to send a voice message which will automatically be converted to text through a proprietary system. Similarly, users can use audio effects to transform their voice while sending a message. In both situations, the audio data will transit through our servers under a heavily encrypted form (combination of server-side encryption and default encryption at rest to ensure complete security) in order to obtain the transcribed version. Only audio data may be shared for this purpose (no other data, such as the user's IP address or any information about a user account is shared). To be noted that those audio samples will not be used for the purpose of identifying you but only to offer you a powerful feature to use with friends of your choice. While using Vocalz, you can also choose to activate our voice cloning feature and be able to generate a text-to-voice transcription. While doing so, you therefore agree that your voice information will be collected and used to transform a text message into a vocal message, only for the conversation channels on which you have given your explicit consent. At any time, you can opt out from that feature by sending us an email at support@vocalz.ai. To be noted that all past messages that have been transcribed using the text-to-voice feature will remain available in the respective conversation channels. Since AI VOICE MESSAGING may rely on a third party for text-to-voice conversion, the audio data that users choose to use to create a voice cloning which eventually converts text to audio may be shared with a third-party in order to obtain their transcribed versions. Only audio data may be shared for this purpose (no other data, such as the user's IP address or any information about their account is shared). AI VOICE MESSAGING will pay for the transcriptions on behalf of its users and third-party may only access the audio data to provide transcribed versions – it will not log transcripts, and will not use the data for any other products or services they offer.
	5. WHAT IF WE TRANSFER YOUR PERSONAL DATA TO THIRD COUNTRIES? Our Services are global by nature and your Personal Data can therefore be transferred and processed in countries other than your country of residency with different data protection laws being applicable. For instance, for users based in the European Economic Area (“EEA”), we may transfer personal data to countries outside the EEA. In any case, such data transfers are always based on appropriate safeguards in accordance with Applicable Regulations, including (a) the standard contractual clauses developed by the European Commission; (b) the decisions of adequacy of the European Commission; or (c) binding corporate rules.
	6. HOW LONG DO WE STORE YOUR PERSONAL DATA FOR? 6.1 Retention AI VOICE MESSAGING shall store your Personal Data for as long as necessary for the purposes identified in this Privacy Policy, including to provide our Services, or for other legitimate purposes, such as complying with legal obligations, enforcing and preventing violations of our Terms, to fight spam, or protecting or defending our rights, property and users. You are hereby informed that AI VOICE MESSAGING reserves the right to store your Personal Data in its temporary archives where strictly necessary to defend its rights in the event of a dispute, for the applicable limitation period. Except for any legal obligation that sets a longer data retention period, at the end of these periods, the personal data processed will be deleted. We may keep activity data on a non-identifiable basis to improve our Services. 6.2 Account Deletion Please note that deletion of the App (i.e. uninstall the App from your device) will not delete your account. However, you can choose to delete your account at any time, by going to your profile settings. Once you initiate the deletion process for your account, that account can no longer be used (i.e. you cannot access any content, including message history, as it will be deleted). However, please remember that when your account is deleted, it does not affect your information related to the groups you created, or the information other users have relating to you, such as their copy of the messages you sent them. If you remain inactive for a period of 3 years after the final user action, we may also send you an email to inform you of the deletion of your account. When you delete your account or when it is deleted as a result of inactivity, we delete the information we have about you. Note that for technical reasons, it takes up to 90 days from the beginning of the deletion process to delete or de-identify your Vocalz information. In limited circumstances, we do retain some information after your account is deleted: ● If we are analysing or investigating a security incident, in order to maintain the security of our Services, we need to retain log and troubleshooting information associated with the incident that we are reviewing past the normal 90-day deletion period ● Copies of certain log records remain in our database but are disassociated from personal identifiers which are used for example to measure performance, reliability and efficiency and to operate and improve our Services. Your account initially was linked to these records by a randomly generated identifier. To disassociate this information when your account is deleted, we delete the link between this identifier and your account as part of the account deletion process ● Copies of your information may also be retained for legal reasons under specific circumstances
	7. HOW DO WE PROTECT YOUR PERSONAL DATA? Your Personal Data may be processed, as described in this privacy policy, through both automated and manual procedures and may be stored at our premises and/or on our service providers’ servers. All data is stored heavily encrypted, including with a combination of server-side encryption and default encryption at rest to ensure complete security. We implement technical, organisational, and security safeguards to reduce the risks of damage, loss, improper use and alteration of your personal data, such as but not limited to : access restriction, use of firewalls, data encryption and de-identification/anonymization procedures. Please note that ensuring your Personal Data security requires also that you take appropriate measures when using a device or network to communicate with us or use our App. If you want to avoid any risk, you should not provide any personal data.
	8. HOW CAN YOU EXERCISE YOUR RIGHTS? In accordance with the Applicable Regulations, you have the rights to access, rectify your Personal Data as collected and have them deleted. Under the conditions of the Applicable Regulations, you also benefit from the rights to request the limitation of the processing, the portability of your Personal Data, and the right to object to processing for reasons pertaining to your personal situation when the processing is based on AI VOICE MESSAGING’s legitimate interest. You can also communicate instructions about the fate of your Personal Data in the event of your death. You can also, at any time, and without reason, object to the processing of your Personal Data for the purposes of direct marketing. You can exercise these rights with us by sending your request accompanied by a copy of an identity document by email to the following email address: legal@vocalz.ai or by mail, writing to the following address: AI VOICE MESSAGING, 54, Avenue du Général Leclerc, 92100, Boulogne Billancourt, France. In any case, you may, at any time, submit a claim to the competent national authority (depending on your place of residence).
	9. SPECIFICS 9.1 NO PERSONAL DATA RELATED TO CHILDREN COLLECTED We do not intentionally collect Personal Data from children under the minimum age as defined in Section 2.4 of the Terms of Use. If you suspect that we have obtained personal data from under-aged children, please reach out to us at legal@vocalz.ai. Shall such suspicion be true, we will take appropriate measures to erase such Personal Data and close the underlying user account. 9.2 NO SALE OF PERSONAL DATA Please note that we do not sell our users’ Personal Data. This rule applies to all of our users independently of their country of residence. Consequently, our Californian users can be reassured on the fact they do not have to opt-out to ensure their Personal Data is not sold which is a requirement under the CCPA when a business sells their Personal Data.