CHANL AI PRIVACY POLICY

Last Updated: January 1, 2025 Effective Date: January 1, 2025

1. INTRODUCTION

Elemente, Corp. ("Elemente," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you use our voice AI testing platform, optimization services, websites, applications, and related services (collectively, the "Services").

This Privacy Policy applies to all users of our Services, including visitors, registered users, customers, and individuals whose voice data may be processed through our platform. By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy.

IMPORTANT NOTICE REGARDING VOICE DATA: Our Services involve the processing of voice recordings and biometric voice characteristics. Voice data is considered sensitive personal information under various privacy laws. Please review Section 4 carefully for details about how we handle voice and biometric data.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

Account Information

Name, email address, phone number
Company name and business information
Billing and payment information
Account credentials and authentication data

Service Data

Voice recordings submitted for testing
Call transcripts and metadata
Testing scenarios and parameters
API configuration and integration settings
Customer support communications

Professional Information

Job title and role
Industry and use case information
Technical requirements and preferences

2.2 Information Collected Automatically

Usage Data

Service feature usage and interactions
Performance metrics and analytics
Error logs and debugging information
API calls and response data

Device and Technical Information

IP address and approximate location
Browser type and version
Operating system and platform
Device identifiers and characteristics
Network and connectivity information

Cookies and Tracking Technologies

Session cookies for authentication
Analytics cookies (with consent where required)
Performance and functionality cookies
For details, see our Cookie Policy

2.3 Information from Third Parties

Platform Integration Data

Data from integrated voice AI platforms (Bland, Vapi, Synthflow, etc.)
OAuth tokens and authentication credentials
Platform-specific identifiers and metadata

Business Information Services

Company verification and credit information
Public business records and profiles

3. HOW WE USE YOUR INFORMATION

3.1 Primary Purposes

We use your information to:

Provide and Improve Services

Execute voice AI testing and optimization
Process and analyze voice recordings
Generate performance reports and insights
Maintain and improve Service functionality

Account Management

Create and manage user accounts
Process payments and billing
Provide customer support
Send service-related communications

Safety and Security

Detect and prevent fraud
Monitor for security threats
Enforce our Terms of Service
Comply with legal obligations

3.2 Legal Bases for Processing (GDPR)

For users in the European Economic Area, we process personal data based on:

Contract Performance: Processing necessary to provide our Services
Legitimate Interests: Improving Services, security, and business operations
Consent: For marketing communications and optional data processing
Legal Obligations: Compliance with applicable laws and regulations
Vital Interests: Protecting health and safety in emergency situations

4. VOICE DATA AND BIOMETRIC INFORMATION

4.1 Special Notice About Voice Data

Voice as Biometric Data: Voice recordings and voiceprints are considered biometric data under many privacy laws, including Illinois BIPA, GDPR, and California CPRA. We treat voice data with enhanced security measures.

Voice Data Collection: We collect voice recordings solely for the purposes of:

Testing AI voice agents
Analyzing conversation quality
Generating optimization recommendations
Training our AI testing personas (with explicit consent)

4.2 Voice Data Processing Safeguards

Encryption: All voice data is encrypted in transit and at rest
Access Controls: Strict role-based access limitations
Anonymization: Voice data is anonymized where possible
Retention Limits: Voice recordings are deleted per our retention schedule
No Voice Cloning: We do not create voice clones or synthetic voices of individuals
Purpose Limitation: Voice data is only used for stated purposes

4.3 Consent for Biometric Processing

Where required by law (including Illinois, Texas, Washington, and other states with biometric laws), we obtain explicit consent before collecting or processing biometric voice data. You may withdraw consent at any time by contacting us at privacy@chanl.ai.

4.4 Voice Data Rights

You have specific rights regarding your voice data:

Right to access voice recordings
Right to delete voice data
Right to restrict processing
Right to object to certain uses
Right to data portability

5. INFORMATION SHARING AND DISCLOSURE

5.1 We Do Not Sell Personal Information

We do not sell, rent, or trade your personal information to third parties for their commercial purposes.

5.2 How We Share Information

We may share information in the following circumstances:

Service Providers

Cloud infrastructure providers (AWS, Google Cloud)
Payment processors
Analytics and monitoring services
Customer support tools
Professional service providers

Platform Partners

Voice AI platforms (only with your authorization)
Integration partners (with consent)
Technology partners for service delivery

Legal and Safety

To comply with legal obligations
To respond to lawful requests and legal process
To protect rights, property, and safety
To detect and prevent fraud or security issues

Business Transfers

In connection with mergers, acquisitions, or asset sales
During bankruptcy or dissolution proceedings

Aggregated Information

We may share aggregated, anonymized data that cannot identify individuals

5.3 International Data Transfers

We may transfer data internationally. We ensure appropriate safeguards through:

Standard Contractual Clauses (EU)
Data processing agreements
Adequacy determinations where applicable
Additional security measures

6. DATA RETENTION

6.1 Retention Periods

We retain personal information for as long as necessary to:

Provide requested services
Comply with legal obligations
Resolve disputes
Enforce agreements

Specific Retention Periods:

Account information: Duration of account plus 3 years
Voice recordings: 90 days unless extended by customer
Testing data: 1 year from test completion
Billing records: 7 years per legal requirements
Marketing data: Until opt-out or 3 years of inactivity

6.2 Deletion Procedures

Upon expiration of retention periods or valid deletion requests:

Data is permanently deleted from production systems
Backups are purged within 90 days
Deletion is verified through audit logs

7. YOUR PRIVACY RIGHTS

7.1 Rights for All Users

Regardless of location, you have the right to:

Access your personal information
Correct inaccurate information
Request deletion of your data
Opt-out of marketing communications
Request information about our data practices

7.2 California Privacy Rights (CCPA/CPRA)

California residents have additional rights:

Right to Know

Categories of personal information collected
Sources of personal information
Purposes for collection and use
Categories of third parties with whom we share data
Specific pieces of personal information

Right to Delete

Request deletion of personal information
Exceptions apply for legal and operational requirements

Right to Correct

Request correction of inaccurate information

Right to Limit Use of Sensitive Personal Information

Limit use of sensitive data (including biometric data)
Opt-out of certain processing activities

Right to Non-Discrimination

No discrimination for exercising privacy rights
Equal service and pricing regardless of privacy choices

Do Not Sell or Share

We do not sell personal information
To opt-out of sharing for cross-context behavioral advertising: [Do Not Sell or Share My Personal Information]

Authorized Agents

You may designate an agent to make requests
Agents must provide proof of authorization

7.3 European Privacy Rights (GDPR)

EEA residents have additional rights:

Data Subject Rights

Right to access (data portability)
Right to rectification
Right to erasure ("right to be forgotten")
Right to restrict processing
Right to object to processing
Rights regarding automated decision-making

Consent Withdrawal

Withdraw consent at any time
Does not affect lawfulness of prior processing

Supervisory Authority Complaints

Lodge complaints with data protection authorities

7.4 Other State Privacy Rights

Colorado (CPA)

Similar rights to CCPA
Right to opt-out of profiling
Universal opt-out mechanisms honored

Virginia (VCDPA)

Consumer rights similar to CCPA
Right to appeal decisions

Connecticut, Utah, and Other States

Rights vary by state
Contact us for state-specific information

8. EXERCISING YOUR RIGHTS

8.1 How to Submit Requests

Online Form: [Privacy Rights Request Form] Email: privacy@chanl.ai Phone: 1-800-XXX-XXXX Mail: Chanl AI Privacy Team, [Address]

8.2 Verification Process

To protect your privacy, we verify identity before processing requests:

Account holders: Login credentials
Non-account holders: Information matching
Authorized agents: Written authorization
Additional verification for sensitive requests

8.3 Response Timeline

Acknowledgment: Within 10 business days
Response: Within 30-45 days (varies by law)
Extensions: May extend by additional 30-45 days with notice

9. DATA SECURITY

9.1 Security Measures

We implement industry-standard security measures:

Technical Safeguards

AES-256 encryption at rest
TLS 1.3 encryption in transit
Multi-factor authentication
Regular security audits and penetration testing
Intrusion detection and prevention systems

Organizational Safeguards

Role-based access controls
Security training for personnel
Confidentiality agreements
Vendor security assessments
Incident response procedures

Physical Safeguards

Secure data centers
Access controls and monitoring
Environmental controls

9.2 Data Breach Notification

In the event of a data breach:

Affected individuals notified within 72 hours (where required)
Regulatory notifications per legal requirements
Breach details and mitigation steps provided
Credit monitoring offered where appropriate

10. CHILDREN'S PRIVACY

Our Services are not directed to children under 16. We do not knowingly collect personal information from children. If we discover we have collected information from a child, we will promptly delete it. Parents who believe we have information about their child should contact privacy@chanl.ai.

11. MARKETING AND COMMUNICATIONS

11.1 Marketing Preferences

Opt-In Communications

Promotional emails (with consent)
Product updates and newsletters
Event invitations
Marketing surveys

Transactional Communications

Service notifications
Security alerts
Billing and payment notices
Legal updates

11.2 Opting Out

Email: Unsubscribe link in emails Account Settings: Manage preferences Contact: privacy@chanl.ai

12. COOKIES AND TRACKING

12.1 Cookie Categories

Essential Cookies

Authentication and security
Load balancing
User preferences

Analytics Cookies (with consent)

Usage patterns
Performance metrics
User experience optimization

Marketing Cookies (with consent)

Ad effectiveness
Remarketing (limited)
Conversion tracking

12.2 Cookie Management

Browser Controls: Adjust browser settings Cookie Banner: Manage preferences Global Privacy Control: We honor GPC signals

13. THIRD-PARTY SERVICES AND LINKS

Our Services may contain links to third-party websites and services. We are not responsible for their privacy practices. We encourage you to review their privacy policies before providing personal information.

14. CALIFORNIA PRIVACY DISCLOSURE

14.1 California Shine the Light

California residents may request information about disclosures to third parties for direct marketing. We do not share personal information for third-party direct marketing.

14.2 California Do Not Track

We honor Do Not Track signals by not tracking users across third-party websites.

14.3 CCPA Metrics (Previous Year)

Requests Received:

Access requests: [Number]
Deletion requests: [Number]
Opt-out requests: [Number]

Response Metrics:

Average response time: [Days]
Requests complied with: [Percentage]
Requests denied: [Number and reasons]

15. INTERNATIONAL USERS

15.1 EU/EEA/UK Users

Data Controller: Chanl AI, Inc. EU Representative: [Name and Contact] UK Representative: [Name and Contact] Lawful Basis: See Section 3.2 Data Protection Officer: dpo@chanl.ai

15.2 Cross-Border Transfers

We transfer data internationally using:

Standard Contractual Clauses
Adequacy decisions
Your explicit consent
Other valid transfer mechanisms

16. AUTOMATED DECISION-MAKING

16.1 AI Processing Disclosure

Our Services use artificial intelligence for:

Voice analysis and scoring
Pattern recognition
Performance optimization recommendations
Anomaly detection

16.2 Your Rights

You have the right to:

Request human review of automated decisions
Understand the logic involved
Challenge automated decisions
Opt-out where legally required

17. CHANGES TO THIS POLICY

We may update this Privacy Policy to reflect:

Changes in our practices
New legal requirements
Service enhancements

Notification Methods:

Email for material changes
Website notice
In-app notifications

Effective Date: Changes effective 30 days after posting unless stated otherwise

18. ACCESSIBILITY

This Privacy Policy is available in alternative formats:

Screen reader compatible version
Large print version
Additional languages upon request

Contact accessibility@chanl.ai for assistance.

19. CONTACT INFORMATION

19.1 General Privacy Inquiries

Chanl AI Privacy Team Email: privacy@chanl.ai Phone: 1-800-XXX-XXXX Mail: Chanl AI, Inc. Attn: Privacy Team [Address]

19.2 Data Protection Officer

Email: dpo@chanl.ai Phone: [DPO Phone]

19.3 EU Representative

[Representative Name] [EU Address] Email: eu-privacy@chanl.ai

19.4 UK Representative

[Representative Name] [UK Address] Email: uk-privacy@chanl.ai

20. REGULATORY INFORMATION

20.1 Supervisory Authorities

California Privacy Protection Agency Website: https://cppa.ca.gov Contact Form: [CPPA Contact]

European Data Protection Authorities List: https://edpb.europa.eu/about-edpb/board/members_en

UK Information Commissioner's Office Website: https://ico.org.uk Phone: 0303 123 1113

20.2 Legal Basis Summary

| Processing Activity | Legal Basis | Data Categories | |-------------------|-------------|-----------------| | Service Delivery | Contract | Account, Service Data | | Security | Legitimate Interest | Technical, Usage | | Marketing | Consent | Contact, Preferences | | Legal Compliance | Legal Obligation | All categories | | Voice Analysis | Consent/Contract | Voice, Biometric |

BY USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.

Version: 1.0 Document ID: PP-2025-001 Language: English