Privacy policy

1.1 Scope of This Policy

We determine how personal information is processed for account administration, billing, security, support, and our own business communications. Where we process Meeting Content on behalf of a business customer, we follow its lawful instructions under the applicable agreement. Our respective privacy responsibilities depend on the processing involved and applicable law. A data processing agreement applies where required.

External communication platforms, browsers, operating systems, payment services, and other third parties may independently process information under their own privacy policies, as described in Sections 6 and 15. If an organization provides your account, its privacy and workplace policies may also apply. These separate arrangements do not limit our obligations under this Policy or applicable law.

This Policy does not cover employment or contractor records collected outside the Service.

1.2 Changes to This Policy

We may update this Policy to reflect changes in the Service, our processing practices, provider arrangements, or applicable law. The revised Policy will identify its effective date. We will provide reasonable advance notice of material changes through the Service, your account email, or another appropriate method where practicable, and any notice required by law. Changes needed to address urgent legal or security matters may take effect sooner.

Before using personal information for a materially different purpose, we will provide any required notice and obtain any consent or other authorization required by applicable law. Updating this Policy does not, by itself, authorize a new use of personal information, expand the scope of an existing consent, or override a valid privacy choice.

1.3 Participant Notices and Authorizations

The Spokked user is responsible for providing required participant notices and obtaining the consents, permissions, releases, and other authorizations necessary for the processing they initiate, as described in Section 5.5 of the Terms. These must cover the relevant features, information, purposes, and processing by the Company and its providers, and satisfy applicable legal, contractual, professional, meeting-policy, and provider requirements.

Users must provide participants with clear information before activating features that process their speech, including participants joining by telephone or entering later.Users must not assume that Spokked or the meeting platform will notify participants or obtain the necessary authorizations on their behalf. A platform permission, meeting invitation, host approval, or continued attendance does not by itself establish every required authorization.

This Policy is available to participants without an account, and they may contact us at voice@spokked.ai. The user’s responsibilities do not limit any notice, consent, or other obligation imposed directly on the Company by applicable law. Objections, withdrawal, and privacy requests are addressed in Sections 11 and 18.

2.1 Account and Contact Information

We collect the email address you use to register and access your account, together with account identifiers, authentication and session records, settings, and communication preferences. We also collect any name, organization, or additional contact details you provide.

If you sign in through an email link or another supported authentication method, we process the information needed to verify access, maintain your session, and protect your account, including related authentication events and security records.

2.2 Speech and Meeting Content

Depending on the features activated, we process microphone audio, meeting audio made available through supported permissions or audio configurations, recognized speech, typed text, transcriptions, translations, subtitles, and generated synthetic speech (collectively, “Meeting Content”). A meeting includes a call, conference, conversation, or other supported communication session. The information processed depends on the application, integration, audio source, permissions, settings, and features in use.

Meeting Content may include the account holder’s speech, other participants’ speech, and information spoken or entered about people who are not present. It may reveal names, identities, opinions, professional activities, business relationships, confidential information, or other personal details. We may receive and process this information even if the affected person does not have a Spokked account or has never interacted directly with us.

Outgoing translation processes the user’s speech or text to generate translated output, including synthetic audio that may be heard by other participants. Translated listening and subtitle features may process other participants’ speech to produce output for the account holder. The processing and visibility of that output depend on the enabled functionality and meeting configuration; subtitles and translated listening output are not necessarily shared with everyone in the meeting.

Processing Meeting Content may involve transmitting relevant information to the technology providers described in Section 6. Processing in real time does not necessarily mean that every component operates without buffering, storage, or processing records. Retention and deletion are addressed in Section 9. References to Meeting Content do not imply that Spokked creates, retains, or makes available a complete recording or transcript of every session.

2.3 Voice Enrollment and Personalized Voices

If you choose to create a personalized voice, we process the recordings and related information submitted through the enrollment workflow. Depending on the workflow, this may include a spoken consent statement, reading samples, voice characteristics derived from those samples, the resulting voice model, associated voice identifiers, and records documenting enrollment, verification, consent, changes, or deletion.

A voice model is a technical representation derived from voice samples and used to generate synthetic speech. It is distinct from the original recordings and from individual audio outputs. Relevant enrollment information, samples, models, or identifiers may be processed by the voice-technology providers described in Section 6 to create, operate, and support the requested feature.

We may also process information reasonably necessary to assess whether enrollment is authorized, perform applicable verification checks, investigate reported impersonation or unauthorized voice use, and prevent misuse. These activities do not guarantee that every unauthorized enrollment will be detected. The classification of voice and verification information, and any additional notice, consent, or retention requirements, are addressed in Section 12.

Only an eligible account holder’s own adult voice may be submitted for personalized voice creation. Users must not submit another person’s voice for that purpose, even with that person’s permission. Processing a participant’s speech for translation does not authorize its use to create a reusable personalized voice model. Choosing a stock voice does not require enrollment of your own voice, although the speech or text needed for the selected translation or synthesis feature is still processed.

2.4 Usage and Transaction Information

We process information about the features and commercial arrangements associated with your account, including plan selection, subscription status, billing periods, introductory and purchased credit allocations, credit-pack purchases, usage duration, credit consumption, and changes to your plan. This includes records of upgrades, downgrades, renewals, cancellations, refunds, and related adjustments.

Transaction information may include purchase amounts, currency, transaction identifiers, payment status, billing contact details, location and tax information, and records relevant to payment failures, fraud checks, or disputes. Where a monetary billing balance is applied toward a payment, we process the corresponding balance and adjustment records. A monetary billing balance is distinct from credits used to measure Service usage.

Payment-method details are collected through the applicable payment interfaces. The information made available to Spokked depends on the transaction and integration and may include a payment-method description, limited payment identifiers, and information needed to reconcile a purchase, administer a subscription, or address a billing issue. This does not mean that Spokked receives every payment detail submitted to the payment provider.

Section 6.7 describes Stripe Managed Payments, Sold through Link, LLC’s role as merchant of record, and the information exchanged for payment administration. Billing and transaction records may remain subject to lawful retention requirements after cancellation or account deletion, as described in Section 9.

2.5 Device and Technical Information

When you access or use the Service, we collect technical information associated with your device, connection, and activity. Depending on the interface and configuration, this may include your IP address, browser and operating-system information, application or extension version, timestamps, session identifiers, language settings, connection information, feature events, error reports, diagnostic records, and security logs.

This information helps us authenticate sessions, maintain compatibility, deliver requested functionality, diagnose failures, measure technical performance, and detect unauthorized access or misuse, as described in Section 3. Technical records may be associated with an account or session where necessary for those purposes.

We may infer an approximate location from an IP address. This is different from collecting precise device location. The information available to us varies by application, integration, device permissions, and settings; access to one supported function does not imply unrestricted access to unrelated device content, communications, or accounts.

Cookies, local storage, similar technologies, and the choices applicable to them are addressed in Section 10. Microphone, audio-routing, browser, and operating-system permissions determine which supported sources are available to the Service, but do not replace any notice or authorization required to process another person’s information.

2.6 Communications and Requests

When you contact us for support, submit feedback, report a security issue or unauthorized voice use, or exercise a privacy right, we process the information you provide and the records reasonably necessary to handle the matter. This may include your name, contact details, account or transaction references, correspondence, attachments, relevant meeting context, and records of our investigation, response, or resolution.

Where reasonably necessary, we may request additional information to verify your identity or authority, locate the affected information, investigate a specific incident, or coordinate with the responsible customer or provider. Verification must be proportionate to the request and the risks involved. You do not need to create an account to contact us or submit a privacy request.

Please provide only information relevant to the matter. Avoid sending complete meeting recordings, identification documents, payment credentials, or sensitive information unless reasonably necessary and requested through an appropriate channel. If your submission includes another person’s information, disclose only what you are authorized to provide and what is needed for the request.

Support and request records are handled under the retention principles in Section 9. Meeting speech, voice samples, and other User Content do not become product feedback merely because they are processed through the Service or submitted to resolve a support issue.

2.7 Sensitive Information in Conversations

Meeting Content and other submissions may reveal health information, political opinions, religious beliefs, financial details, biometric information, or other information subject to heightened legal protection. Such information may concern the account holder, another participant, or someone who is not present. Its classification depends on the information, processing activity, and applicable law; not every voice recording or voice model constitutes biometric or special-category data.

Conversations may also contain information protected by confidentiality agreements, professional secrecy, legal privilege, trade-secret restrictions, or workplace obligations, whether or not it qualifies as sensitive personal information under privacy law. Processing through Spokked may involve disclosure to the Company and relevant providers. A user’s ability to access information does not necessarily authorize that disclosure.

Users must not submit or cause the Service to process information they are prohibited from disclosing. Before using Spokked for a confidential, privileged, regulated, or sensitive conversation, they must establish that the intended processing is permitted and that any required notices, authorizations, safeguards, and contractual arrangements are in place. Section 5.7 of the Terms addresses these responsibilities.

An ordinary subscription does not itself establish a specialized arrangement for regulated data or guarantee preservation of legal privilege. Where additional legal conditions apply, processing must satisfy those conditions before it begins. The voice and biometric provisions in Section 12 supplement this Section. Nothing here limits obligations that applicable law imposes directly on the Company.

3.1 Operating the Service

We use account, contact, and technical information to register users, authenticate access, maintain sessions and preferences, and provide the features requested through the Service. This includes managing access permissions and supporting the applications, extensions, integrations, and configurations through which Spokked is used.

We process Meeting Content to recognize speech, produce transcriptions and translations, generate subtitles or synthetic speech, and deliver the corresponding output. If you enroll a personalized voice, we use the relevant samples, voice model, identifiers, and enrollment records to create, operate, and manage that feature.

For account holders, processing necessary to provide the contracted Service is undertaken to perform our agreement with them. Optional features and processing subject to additional requirements are supported by separate consent or other authorization where required. An agreement with an account holder does not itself authorize processing another participant’s information.

3.2 Processing Meeting Content

When we process Meeting Content on behalf of a business customer, we follow its documented, lawful instructions under the applicable agreement. The customer is responsible for ensuring that the processing it initiates is authorized, providing required notices, and obtaining the necessary consents, permissions, and other authorizations. Participant notices and responsibilities are addressed in Section 1.3 of this Policy and Section 5 of the Terms.

Where we independently determine a processing purpose, we remain responsible for satisfying the requirements applicable to that activity. Where permitted, we may process relevant information for legitimate interests in enabling requested business communications, maintaining a reliable service, preventing misuse, or protecting legal rights, after considering the necessity of the processing and its impact on affected individuals.

These interests do not replace consent or additional protections required for communications, recordings, biometric information, or other sensitive data. Participants may exercise the applicable rights described in Section 11.

3.3 Managing Subscriptions and Payments

We use account, usage, and transaction information to administer plans and subscriptions, allocate and meter credits, apply billing balances, manage renewals and plan changes, reconcile payments, and handle cancellations, refunds, or billing disputes.

We also use relevant records to maintain accurate accounts, meet tax and recordkeeping obligations, and coordinate payment-related matters with Stripe and the merchant of record described in Section 6.7. Processing serves the performance of the applicable purchase or subscription, compliance with legal obligations, and our legitimate interests in accurate billing and resolving payment issues.

3.4 Protecting Accounts and Preventing Misuse

We use relevant account, technical, usage, verification, and incident information to protect access, detect suspicious activity, investigate fraud or unauthorized voice use, enforce applicable restrictions, and respond to security incidents.

Where necessary and lawful, an investigation may involve reviewing specific Meeting Content, enrollment material, or other records relevant to the reported issue. Access is restricted to authorized personnel and providers who need the information for that purpose.

This processing supports our legitimate interests in protecting the Service, users, participants, and others, and compliance with applicable legal obligations. Any additional requirements for sensitive or biometric information apply separately.

3.5 Providing Support and Improving Performance

We use support communications and relevant account, usage, and technical information to respond to requests, investigate errors, resolve technical problems, and improve the Service’s reliability, compatibility, and usability. This processing supports our contractual support activities and legitimate interests in maintaining and improving the Service. Optional analytics are subject to the notice and consent requirements described in Section 10.

Operational analysis and troubleshooting do not themselves authorize training general-purpose AI models on private Meeting Content, enrollment samples, or personalized voice models. Any separate model-improvement use is subject to Section 12.4. Meeting Content does not become product feedback merely because it is processed through Spokked or reviewed to resolve an issue.

3.6 Communicating and Meeting Legal Obligations

We use contact and account information to send authentication messages, security alerts, billing communications, support responses, and notices about material changes. Promotional communications are handled separately under Section 4, with consent where required.

We may also process relevant information to comply with legal obligations, respond to valid legal process, investigate complaints, establish or defend claims, and protect legal rights. Depending on the activity, this processing is necessary to meet a legal obligation or pursue a legitimate interest in resolving disputes and protecting affected persons.

3.7 Information Required for Particular Features

Certain information is necessary to provide the feature you request. Account-based access requires an email address and relevant authentication and technical information. Speech translation requires processing the corresponding audio or text. Personalized voice creation requires your enrollment samples and the resulting voice model; a stock voice may be available without enrolling your own voice.

If you decline or withdraw a permission or consent necessary for a particular feature, that feature may be unavailable or stop operating. Optional processing is not a condition of unrelated functionality. Declining marketing or optional analytics does not, by itself, prevent access to the core Service. Available controls and the effects of withdrawal are described in Sections 10 and 18.

4.1 Service Communications

We may send account-access links, security alerts, billing notices, support responses, and information about material changes. These communications are related to operating the Service and may continue even if you opt out of promotional messages.

4.2 Promotional Communications

Where permitted by law, we may send information about Spokked features, updates, and offers using contact details you provide. We rely on consent where required or a permitted basis for communicating with existing business contacts. You may unsubscribe through the relevant message or contact voice@spokked.ai. We process opt-outs within applicable deadlines and may retain limited suppression information so that your choice continues to be respected.

We do not use the contents of private meeting conversations, personalized voice models, or voice-enrollment samples to select advertisements for you. Participating in a translated meeting does not by itself enroll a non-user in marketing or authorize us to use a participant’s voice in promotional materials.

5.1 Directly from You

We receive information when you create or access an account, configure preferences, enroll a personalized voice, speak or enter text through enabled features, make a purchase, or communicate with us. This includes information and materials you submit for support, feedback, privacy requests, or reports of misuse.

5.2 From Users and Other Individuals

A Spokked user or business customer may make another person’s speech or information available to the Service through an activated meeting feature. Meeting Content may also include information about individuals who are not present. We may therefore process your personal information even if you have not created an account, visited our website, or provided information directly to us.

We may also receive information from someone reporting unauthorized voice use, submitting a request on another person’s behalf, or providing relevant information during an investigation. Receiving information from another person does not, by itself, establish that its collection or use is authorized.

5.3 Through the Service and Its Providers

We collect technical and usage information through the operation of our websites, applications, extensions, and integrations, including through the technologies described in Section 10.

We also receive information from providers supporting the Service, such as speech-recognition results, translations, generated audio, voice-model identifiers, and payment or subscription updates. The information exchanged depends on the provider’s function and the features used, as described in Section 6.

Information available through an external platform depends on the supported integration and permissions granted. Connecting Spokked to a platform does not give us unrestricted access to your accounts, email, calendar, or unrelated device content.

6.1 Technology and Operational Providers

We disclose personal information to providers supporting the delivery, administration, and protection of the Service, including hosting, infrastructure, authentication, speech recognition, translation, voice synthesis, voice-model management, security, and customer support. Payment providers are addressed separately in Section 6.7.

The information disclosed depends on the provider’s function and the features used. It may include account and technical information, Meeting Content, voice samples, consent and verification records, voice models or identifiers, generated output, and relevant usage information. Disclosures are limited to information reasonably necessary for the applicable purpose and remain subject to contractual arrangements and applicable law.

Where a provider processes information on our behalf, we require the processing, confidentiality, security, deletion, and assistance obligations applicable to that relationship. A provider’s independent processing responsibilities, where applicable, depend on its activities and the governing arrangements.

ElevenLabs supplies technology used in relevant speech and voice functions. Depending on the feature, ElevenLabs and its applicable affiliates and subcontractors may receive and process audio, text, enrollment samples, consent recordings, voice models or identifiers, and generated output to provide and support those functions. This does not grant unrestricted rights to exploit an individual’s voice or identity or use information for unrelated purposes. Provider retention and any separate model-improvement use are addressed in Sections 9 and 12.4.

6.2 Meeting Participants and Business Customers

Using Spokked may make translated speech or other output available to participants through the relevant meeting, communication platform, or audio channel. Subtitles and translated listening output are delivered according to the enabled features and configuration and are not necessarily visible or audible to every participant.

Information communicated through these features may identify the speaker or reveal personal information contained in the original conversation. Participants who receive that information may independently retain or disclose it. Their independent conduct is addressed in Section 15.

Where an organization provides or administers access, we may disclose information necessary to manage that access, administer its Service arrangement, or respond to an authorized request, subject to the applicable agreement, configuration, and law. Organizational access does not automatically include access to every transcript, voice sample, or personalized voice model. The organization is responsible for explaining its own administration and subsequent handling of information.

6.3 Authorized Personnel and Affiliates

Authorized employees, contractors, and relevant affiliates may access personal information where reasonably necessary to operate the Service, provide support, maintain security, investigate misuse, or perform another purpose described in this Policy.

Access is limited according to the person’s responsibilities and the information needed for the task, subject to applicable confidentiality and security requirements. Employment, engagement, or corporate affiliation does not itself authorize unrestricted access to Meeting Content or voice information, or use for an unrelated business purpose.

6.4 Legal Requirements and Protection of Rights

We may disclose relevant information where required by applicable law, a binding order, or valid legal process, or where otherwise legally permitted and reasonably necessary to investigate suspected unlawful activity, address fraud or security threats, protect individuals, establish or defend legal claims, or enforce our agreements.

We assess the authority, scope, and applicable restrictions of a request before responding and limit disclosure to information appropriate to the lawful purpose. We provide notice to the affected person or customer where required and legally permitted. This Section does not authorize disclosures prohibited by privacy, communications, biometric, or other applicable law.

6.5 Corporate Transactions

Personal information may be disclosed in connection with a proposed or completed financing, merger, acquisition, reorganization, insolvency proceeding, or sale or transfer of all or part of the relevant business or assets. Recipients may include professional advisers and prospective or actual counterparties.

Such disclosures remain subject to appropriate confidentiality, access restrictions, and applicable legal safeguards. Information disclosed for evaluating a transaction may be used only within the permitted scope. Following a transfer, the recipient must handle personal information consistently with applicable law and the notices and commitments governing that information, unless changes are lawfully introduced with any required notice or consent.

6.6 Disclosures You Request or Authorize

We may disclose information when you request or direct a supported action, or when you provide valid consent to a specified disclosure. The information, recipients, and purposes must remain within the scope of that request or authorization.

A direction involving another person’s information does not, by itself, establish authority to disclose it. Where we process information on behalf of a business customer, disclosures under its instructions remain subject to the applicable processing agreement and law. Consent to one disclosure does not authorize unrelated uses or disclosures.

6.7 Stripe Managed Payments

Spokked uses Stripe Managed Payments, with Sold through Link, LLC, a Stripe company, acting as merchant of record for purchases through the Service. Stripe and its applicable affiliates handle payment processing, applicable transaction-tax calculation, collection and remittance, fraud checks, payment disputes, and payment-related support. Spokked remains responsible for providing the Service, product functionality, and technical support.

Information processed for these activities may include billing and contact details, billing location, tax information, purchase and subscription records, payment-method information submitted through payment interfaces, transaction identifiers, payment status, fraud indicators, and dispute or refund communications. Information received by Spokked depends on the integration and does not necessarily include all payment details submitted to the payment provider.

We exchange relevant information with the payment parties to administer purchases and subscriptions, reconcile payments, implement authorized billing adjustments, and resolve payment issues. Those parties may independently process and retain information for their own payment, tax, fraud-prevention, dispute-handling, and legal obligations. Deleting a Spokked account does not automatically delete records they must or may lawfully retain for those purposes.

Stripe’s privacy information is available at https://stripe.com/privacy and through the applicable checkout interfaces. The contractual payment arrangements are described in Section 7.5 of the Terms.

We maintain reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, alteration, disclosure, or misuse. These safeguards address account and session security, access permissions, and the handling of information by authorized personnel and providers. The measures applicable to particular processing depend on the nature and sensitivity of the information, the risks involved, and the relevant systems and provider arrangements.

No safeguard can eliminate every risk, and we cannot guarantee that the Service will remain free from unauthorized access or security incidents. This limitation does not reduce our obligations under applicable law or our express contractual commitments.

Users must take reasonable steps to protect their email accounts, authentication links, devices, and active sessions. Report suspected account compromise, unauthorized voice use, or accidental disclosure promptly to voice@spokked.ai. Provide enough information to identify the issue without sending passwords, active sign-in links, complete payment details, or unnecessary sensitive material.

When we become aware of a suspected incident involving personal information, we assess its nature and potential impact and take appropriate steps to investigate, contain, and address it. We may coordinate with affected customers, relevant providers, or competent authorities and preserve information reasonably necessary for the investigation and required records.

We notify affected individuals, customers, and authorities where required by applicable law or our contractual obligations, within the applicable deadlines. Where we process information on behalf of a business customer, we notify and assist that customer as required by the relevant processing agreement and law. Security-related retention or disclosure remains limited to the applicable purpose and legal requirements.

Spokked is operated by Everyrealm Inc., a U.S. company. Personal information may be transferred to, accessed from, stored, or otherwise processed in the United States and other countries where we or our relevant providers operate. The locations involved depend on the feature, provider, and applicable service arrangements.

Privacy laws, individual rights, and rules governing access by public authorities may differ between countries. Where applicable law restricts an international transfer, we use a legally recognized transfer mechanism and any additional safeguards required for that transfer. Depending on the circumstances, these may include an applicable adequacy decision, standard contractual clauses, a recognized UK transfer mechanism, or another arrangement permitted by law.

Where required, we assess the circumstances of the transfer, the protections available in the destination country, and the need for supplementary contractual, technical, or organizational measures. Relevant onward transfers by providers must also comply with the applicable contractual arrangements and legal requirements.

Using Spokked, accepting the Terms, or participating in a meeting does not, by itself, constitute consent to a restricted international transfer or replace a required transfer mechanism. Where processing is performed on behalf of a business customer, the applicable data processing agreement also governs transfer instructions and safeguards.

You may contact voice@spokked.ai for information about the transfer arrangements applicable to your personal information and, where available under applicable law, a copy of the relevant safeguards. We may redact confidential commercial information or information concerning other individuals while preserving the information needed to explain the applicable protections.

9.1 Retention Principles

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, meet applicable legal obligations, and establish, exercise, or defend legal claims. Retention is determined by the category and sensitivity of the information, the feature used, applicable customer instructions, provider arrangements, security needs, and relevant recordkeeping or limitation periods.

An active account does not justify retaining every category of information for the account’s entire lifetime. Different periods may apply to Meeting Content, enrollment samples, voice models, consent records, technical logs, and transaction information. When information is no longer needed and no lawful retention requirement applies, we delete it or render it anonymous in accordance with applicable law. Removing a name or replacing an identifier does not, by itself, make information anonymous.

9.2 Meeting Content and Processing Records

We process Meeting Content to provide the transcription, translation, subtitle, listening, or voice functions activated by the user. This processing may involve temporary buffering, intermediate text or audio, and records maintained by relevant providers. Real-time processing does not necessarily mean that information is never stored or that every provider applies the same retention settings.

Any retention must remain limited to the purposes described in this Policy and the applicable processing arrangements. Relevant content may also be retained where reasonably necessary to address a support request, investigate a specific incident, comply with a preservation obligation, or establish or defend a legal claim. Those circumstances do not authorize unrestricted retention of unrelated conversations.

Where providers act as processors, their deletion or return of information is governed by applicable instructions, agreements, and law. This Policy does not imply that Spokked maintains a complete meeting archive or can retrieve a recording or transcript that is no longer available.

9.3 Voice Samples Models and Consent Records

A personalized voice model and the information needed to operate it are retained while necessary to provide the requested feature, subject to deletion requests, applicable customer instructions, account termination, and legal requirements. Enrollment recordings, reading samples, verification material, and derived voice information are assessed according to their respective purposes and do not automatically share the model’s retention period.

Deleting a personalized voice ends its availability for new generation through the account once the deletion takes effect. Any continued retention of related samples, verification information, or provider-held records must have a separate, lawful justification and remain limited to the relevant purpose.

We may retain evidence of consent, authorization, withdrawal, or action taken in response to suspected misuse where necessary for compliance, accountability, or legal claims. Retaining such evidence does not, by itself, authorize continued use of the voice model or retention of every underlying recording. Additional requirements for biometric information, including applicable destruction deadlines, are addressed in Section 12.

9.4 Account Billing and Support Records

We retain account information, settings, and authentication records as needed to administer access, maintain security, and manage the account. Relevant billing, tax, purchase, payment, refund, and credit-adjustment records may remain after cancellation or account closure where necessary to satisfy recordkeeping obligations, resolve disputes, or prevent fraud.

Support correspondence, privacy requests, incident reports, and investigation records are retained according to the nature of the matter, its resolution, and applicable legal requirements. Limited records may also be retained to document compliance with a request or ensure that a marketing opt-out continues to be respected.

Information retained after account closure remains subject to appropriate access restrictions and safeguards. Its retention does not authorize reuse for unrelated purposes.

9.5 Deletion Controls and Requests

You may delete a personalized voice or your account through the available controls, or contact voice@spokked.ai if those controls are unavailable or do not work. Individuals without an account may also submit deletion requests under Section 11. We may take proportionate steps to verify the request and determine which information and processing activities it concerns.

Account deletion immediately ends access and cancels the associated subscription and future renewals under Section 7.9 of the Terms. It also initiates the applicable deletion process for personal information. The consequences for remaining credits and any refund rights are governed by the Terms and applicable law.

Ending access and completing deletion are separate events. Implementing a request may require coordination with providers or the business customer responsible for the information. We process requests within applicable legal deadlines and explain any permitted extension, refusal, or limitation where required.

We may retain limited information where required or otherwise lawfully justified for a disclosed purpose, including tax obligations, unresolved disputes, security investigations, suppression preferences, or evidence of required notices and authorizations. Any exception applies only to the information and period necessary for that purpose.

Subscription cancellation does not itself delete the account, personalized voice, or retained information. Deleting a voice does not itself cancel a subscription or recall audio already delivered to others. Withdrawing consent stops the relevant future consent-based processing and does not affect processing lawfully completed before withdrawal or retention supported by a separate lawful basis.

9.6 Backups and Independent Copies

Residual copies may remain in protected backups until removed through the applicable backup cycle, subject to legal requirements. Such copies are restricted from ordinary operational use. If a backup is restored, applicable deletion instructions must be reapplied where required so that restoration does not improperly reactivate deleted information or a withdrawn permission.

Provider-held information is subject to the relevant processing role, agreement, and deletion requirements. Where a provider processes information on our behalf, we communicate and implement applicable deletion instructions as required. A provider acting independently may retain information for its own lawful obligations, as described in Sections 6 and 15.

Deleting information from Spokked does not automatically remove recordings, transcripts, messages, generated audio, or other copies independently retained by participants or external platforms. Those parties are responsible for their own handling of that information, and you may need to contact them separately. We notify relevant recipients of a deletion request or completed deletion where applicable law requires.

10.1 Essential Technologies

Our websites, applications, extensions, and other supported interfaces may use cookies, local storage, session identifiers, and comparable technologies to authenticate access, maintain sessions, remember necessary settings, secure the Service, and support requested functionality. These technologies may process account identifiers, technical information, and usage events. Their availability and operation depend on the relevant interface and configuration.

10.2 Optional Analytics and Marketing Technologies

If optional analytics or marketing technologies are used, we identify their purposes and provide the choices required by applicable law through the relevant consent or preference mechanism. Where consent is required, optional technologies are not activated until that consent is obtained. A future change to tracking practices is subject to the notice and choice requirements described in this Policy.

You may manage available preferences through the Service or your browser settings. Blocking essential storage may affect sign-in or other requested functionality. Removing cookies may reset browser-specific choices. Device, browser, and operating-system permissions can also be reviewed or revoked through their settings; revocation may disable the corresponding audio feature.

10.3 Privacy Preference Signals

Where applicable law requires recognition of a universal opt-out mechanism, including Global Privacy Control, we honor qualifying signals for the processing to which they legally apply. A signal does not ordinarily cancel a subscription, delete an account, or withdraw consent for unrelated voice features. General browser “Do Not Track” settings are not necessarily equivalent to a legally recognized opt-out signal.

10.4 Chrome Extension

The use of information received from Google APIs will adhere to the Chrome Web Store User Data Policy, including the Limited Use requirements.
https://developer.chrome.com/docs/webstore/program-policies/limited-use/

In a Google Meet call, the Spokked extension detects on your device when you turn Meet’s captions on or off (by clicking Meet’s captions button or pressing C) so it can restore your caption setting. It does not record what you type or where you click. It sends Spokked’s servers only two things: whether your microphone is muted, and playback quality counts (audio buffer levels and gaps). It reads Meet’s connection statistics on your device to check whether it can hear the other participants.

11.1 Rights and Available Choices

Depending on applicable law, your location, and our role in the processing, you may have the right to:

• Confirm whether we process your personal information and obtain information about its collection, use, sources, and disclosure;
• Access your personal information and receive a copy in a portable format;
• Correct inaccurate or incomplete information;
• Request deletion, anonymization, or restriction of information where applicable;
• Object to certain processing, including processing based on legitimate interests;
• Withdraw consent where processing relies on that consent;
• Opt out of the sale of personal information, sharing for cross-context behavioral advertising, targeted advertising, or qualifying profiling;
• Limit certain uses or disclosures of sensitive personal information; and
• Obtain information about consent choices and the consequences of declining consent.

These rights apply within the scope and conditions of the relevant law and may be subject to exceptions. Withdrawal of consent does not affect processing lawfully completed before withdrawal or retention supported by a separate lawful basis. Where applicable, you may object to direct marketing at any time, including related profiling.

We do not sell personal information for monetary consideration or use private Meeting Content, enrollment samples, or personalized voice models for cross-context behavioral advertising. If another disclosure constitutes a sale, sharing, or targeted advertising under applicable law, we provide the required information and choices and honor applicable opt-out preference signals, as described in Section 10. We do not knowingly sell or share personal information of individuals under sixteen (16).

The categories of information, sources, purposes, recipients, and retention practices are described in Sections 2 through 10, including disclosures concerning the preceding twelve months where required. Any additional use of sensitive information remains subject to applicable restrictions, notice requirements, and rights to consent or limit processing.

11.2 Submitting and Verifying Requests

You may exercise an applicable right by contacting voice@spokked.ai or using the available account controls. You do not need to create an account to submit a request.

Please identify the right you wish to exercise and provide enough information to locate the relevant records. For meeting-related requests, useful details may include the approximate date, the account holder or organization involved, and the processing concerned. Avoid submitting complete recordings, identification documents, or unnecessary sensitive information unless reasonably necessary and requested through an appropriate channel.

We may take proportionate steps to verify your identity, authority, or relationship to the information before disclosing or changing records. Verification requirements depend on the request and applicable law; we do not require identity verification for an opt-out where the law prohibits it. An authorized representative may submit a request where permitted, subject to applicable proof of authority and verification requirements.

We acknowledge and respond to requests within the deadlines required by applicable law. Where a permitted extension is necessary, we provide the required notice and explanation. Requests are generally free, although a reasonable fee or refusal may be permitted in specified circumstances. If we cannot fulfill a request in whole or in part, we explain the applicable reason and available review or appeal rights where required.

Information collected to verify or administer a request is used only for appropriate request-handling, security, and related compliance purposes. We do not unlawfully discriminate or retaliate against anyone for exercising a privacy right.

11.3 Meeting Participants and Business Customers

Participants without a Spokked account may contact us about their personal information, unauthorized voice use, or a privacy concern through the same channels available to account holders.

Where we process information on behalf of a business customer, we may coordinate with or refer the request to that customer so it can determine the appropriate response. We assist as required by the applicable agreement and law. This does not prevent you from contacting us about processing for which we are independently responsible or requesting assistance in identifying the responsible customer.

For an immediate objection during a meeting, notify the Spokked user or meeting host. Our Terms require the user to stop the affected processing when a participant objects or withdraws consent. If the participant’s audio cannot be excluded, the user must disable the relevant feature or stop using Spokked for that meeting. An email request does not itself disable a live session.

Stopping future capture, withdrawing consent, deleting retained information, deleting a personalized voice, and closing an account are separate actions. Their respective effects are explained in Sections 9 and 18.

11.4 Appeals and Complaints

If we deny a request and applicable law provides a right of appeal, you may appeal by emailing voice@spokked.ai with “Privacy Appeal” in the subject line. Identify the request, our response, and the reasons you believe the decision should be reconsidered. We review and respond within the applicable deadline and provide information about further complaint options where required.

You may also raise a concern with the competent privacy, data protection, or other supervisory authority. Where applicable, this may include the authority in your place of residence or work or where the alleged infringement occurred. You do not need to complete our internal complaint process before contacting an authority where the law permits a direct complaint.

Nothing in this Policy limits a privacy right, regulatory complaint, or remedy that applicable law does not permit us to restrict.

12.1 Personalized Voice Creation

Section 2.3 describes the information processed to create and operate a personalized voice. The additional requirements in this Section apply where enrollment, verification, or subsequent use involves biometric or other sensitive information under applicable law. Any required separate notice and consent must be provided before the relevant processing begins.

12.2 Verification and Biometric Information

Voice recordings and models are personal information when linked or reasonably linkable to an individual. Particular processing, including deriving a voiceprint to identify or authenticate a person, may also constitute biometric, sensitive, or special-category processing under applicable law. We do not assume that calling a feature “voice verification” removes those requirements.

Before collecting or using biometric information where additional rules apply, we provide the required written information about the specific purpose, intended use, recipients, and retention or destruction period, and obtain the required consent or written release. We do not rely solely on a user’s acceptance of general Terms or this Policy for that authorization.

12.3 Biometric Retention and Disclosure

Biometric information, where processed, is subject to a specific retention and permanent-destruction schedule and any shorter applicable legal limit. It is not sold, leased, traded, or otherwise commercially exploited as biometric information. Disclosure occurs only with the authorization or other legal basis required by the applicable biometric law and with required safeguards.

For biometric identifiers or information subject to the Illinois Biometric Information Privacy Act, the retention schedule requires permanent destruction when the initial purpose is satisfied or within three years after the individual’s last interaction with the relevant entity, whichever occurs first, subject to a valid court-issued warrant or subpoena. A more specific enrollment notice may require earlier destruction. These requirements do not imply that every recording or voice model is necessarily an Illinois biometric identifier.

12.4 AI Providers and Model Improvement

Spokked uses third-party AI services for requested speech recognition, translation, synthesis, and related functions. Information supplied to a provider depends on the feature and may include speech, recognized or translated text, enrollment samples, consent recordings, voice identifiers, voice models, and generated output. Relevant providers may retain processing records under the applicable service configuration and contractual arrangements. Deletion may require separate steps with a provider. A function described as real time is not necessarily a function with no retention.

The permissions in the Terms to process User Content do not themselves authorize training general-purpose AI models on private Meeting Content, enrollment samples, or personalized voice models. A separate model-improvement use must be specifically disclosed, supported by an independently sufficient lawful basis, and subject to any required separate consent. Accepting general Terms or attending a meeting does not supply that consent. Generating and operating a personalized voice at the account holder’s request, and necessary security or technical processing, are distinct from a separate general-purpose model-training use.

Retention and model-improvement settings can differ across providers, plans, products, and processing functions. We do not promise universal zero retention or that deleting an account automatically deletes all provider-held information. The applicable arrangements and configured controls must support the processing described in this Policy and any relevant customer agreement or feature notice. We provide required information and choices before a separate use begins. ElevenLabs’ public privacy information is available at https://elevenlabs.io/privacy-policy; that public notice does not replace the terms and settings applicable to processing performed for Spokked.

12.5 Automated Controls and Human Review

AI generates translations, subtitles, and synthetic speech. Automated controls may also flag suspected misuse or affect account access or voice enrollment. These functions are intended to deliver and protect the Service, not to determine eligibility for employment, credit, health care, insurance, or another unrelated significant decision.

If an automated control blocks a feature or account and you believe it is mistaken, contact support to request review. Where applicable law requires particular information, human intervention, an opportunity to contest a decision, or an opt-out, we provide those rights. We do not assume that every security restriction is exempt from applicable automated-decision rules.

An ordinary subscription is not a business associate agreement or a specialized arrangement for regulated information. Unless expressly agreed in a separate written agreement signed by an authorized Company representative, we do not undertake heightened confidentiality, professional-secrecy, data-localization, or sector-specific commitments beyond applicable law and our express agreements. We do not guarantee that use preserves legal privilege or satisfies the duties of a particular profession or industry. These limits do not reduce the privacy, security, or other obligations that law imposes directly on us.

Where a customer acts as controller, it determines its own lawful retention and sharing outside our Service and must maintain its own privacy notices. We follow lawful instructions within the applicable processing agreement and do not use customer responsibility as a waiver of obligations that apply directly to us.

Spokked accounts are intended only for adults aged eighteen (18) or older, and the Service is not directed to children. Users must not enroll a minor’s voice or use the Service to create a voice model identifiable as a particular real minor. They must not initiate processing of children’s information in a manner that violates applicable law or provider restrictions.

If you believe a child has created an account, submitted enrollment material, or had information processed without required authority, contact voice@spokked.ai. We will assess the report and take appropriate steps, which may include restricting processing, removing the account or information, or contacting the responsible customer. Additional protections apply to children’s information regardless of whether the person has an account.

Spokked may operate through or interact with external communication platforms, browsers, operating systems, applications, devices, and other services. Supported functionality depends on the interfaces we make available and may vary by version, permissions, settings, and configuration.

Third parties may independently collect and process account information, device data, meeting content, recordings, and other information under their own terms and privacy policies. Their activities may occur alongside Spokked’s processing without being performed on our behalf. Granting an audio or integration permission does not authorize every subsequent use of information, and a platform’s notice or consent does not automatically cover processing by Spokked.

Payment parties, including Stripe and Sold through Link, LLC, may independently process information for payment administration, fraud prevention, taxes, disputes, and legal compliance. Their functions and applicable privacy information are described in Section 6.7.

Meeting participants may independently record, capture, copy, retain, or disclose speech, subtitles, generated audio, or other material they receive. Such conduct remains subject to applicable law and any relevant permissions, confidentiality obligations, or meeting rules. Using Spokked does not authorize a participant to record or disclose another person’s information.

We do not control independent copies retained by participants or external services. Disabling a feature, deleting a personalized voice, or closing a Spokked account does not recall material already delivered or automatically delete those copies. Requests concerning independently held information may need to be directed to the person or service responsible for it.

These limitations do not reduce our responsibilities for our own processing, disclosures, provider arrangements, or legally required assistance. Where a third party processes information on our behalf, the applicable safeguards and obligations described in this Policy continue to apply. Review the relevant third-party privacy notices and meeting settings to understand how information may be handled outside Spokked.

This Policy is interpreted consistently with applicable privacy and data protection law. A choice of law in our Terms does not remove mandatory privacy rights, restrict the powers of a supervisory authority, or require an individual to give up a remedy that cannot lawfully be waived.

If you accepted the Spokked Terms, their dispute provisions apply only to the extent valid and applicable to the dispute. A meeting participant who has not accepted those Terms is not bound by their arbitration or class-action provisions merely because their information is processed. Anyone may raise a privacy concern at voice@spokked.ai or contact an applicable authority without first using contractual dispute procedures where law permits.

Applicable law controls. A separately executed data processing agreement governs its processing subject matter; this Policy governs our privacy disclosures and practices; and a separately executed commercial agreement governs matters it expressly modifies. The Terms govern remaining contractual use of the Service. A voice, biometric, cookie, or other feature-specific notice supplements the relevant processing and provides any additional information or choices required by law. A consent authorizes only the processing within its valid scope and cannot be expanded by a general provision elsewhere.

No document may authorize processing prohibited by law. If a discrepancy affects your information, contact us for clarification. The existence of a separate customer agreement does not eliminate information or rights we must provide to affected individuals.

Subject to the features available to you, you may manage account preferences, choose a stock voice instead of enrolling a personalized voice, delete a personalized voice, cancel a subscription, delete an account, unsubscribe from marketing, and adjust cookie, microphone, or audio permissions. Contact support if an available control does not work. Subscription cancellation stops renewal while ordinarily preserving access through the paid period; account deletion immediately ends access under the Terms. Neither action automatically deletes every category of information at the same time.

Where processing relies on consent, you may withdraw that consent at any time through the relevant control or by contacting voice@spokked.ai. We will make withdrawal as easy as giving consent where required. Withdrawal does not affect the lawfulness of processing before withdrawal and does not automatically require deletion of records retained on a separate lawful basis. We explain any lawful limitation that affects a request.

A participant may ask the user to disable the relevant meeting feature immediately and may also contact us afterward about retained information. Disabling future capture, deleting a voice model, deleting an account, and unsubscribing from emails are separate actions with different effects. Exercising one choice does not necessarily carry out the others.

After account closure, this Policy continues to explain the handling of information we lawfully retain. It does not authorize indefinite retention or new purposes merely because an account has ended. Required notices, security measures, deletion duties, and privacy rights continue for as long as the applicable information is processed.

The most recent version explains our current practices, but it does not retroactively supply consent or erase commitments applicable to earlier processing. We retain evidence of relevant notices, permissions, and requests where necessary and lawful.

For privacy questions, participant concerns, voice-related requests, or rights requests, contact:

Everyrealm Inc. | Spokked Privacy Team
voice@spokked.ai