Privacy Policy

1. Who is responsible for your data

Assistive Communication, LLC, a Delaware limited liability company, is the controller of the personal information described in this policy. Our contact details are listed in section 14.

2. Information we collect

Account information. When you sign in with Google, Microsoft or Apple we receive an identifier issued by that provider, your email address (Apple may give us a private relay address), your name and, for Google, your profile picture. We never receive your password for those providers.

Profile information you choose to provide. To personalize suggestions you may enter details such as your name, date of birth, nationality, place of residence, occupation, gender, a short introduction or biography, family information, hobbies and interests, frequently used phrases, your communication style and any other additional information. You may also provide health-related information (for example, a medical condition that affects how you communicate). Providing this information is optional and you can edit or remove it at any time.

Conversation content. When you use the App we process the text you write or select and the speech picked up by your device microphone, converted to text, so that we can understand the conversation and generate suggested replies. Depending on the mode you use, we save conversations as threads, meeting transcripts, summaries and titles, and long-term "memories" and short summaries (briefs) about you and your contacts that help produce better suggestions.

Audio. Microphone access is requested only to transcribe speech in real time. Audio is streamed to our speech-recognition provider for transcription and is not stored by Cfluent as audio recordings; only the resulting text is processed and saved as described above.

Contacts. If you create contacts inside the App (for example, the people you talk to), we store the details you enter for them.

Images. If you upload images (such as a profile picture), they are stored in cloud storage linked to your account.

Subscription and payment information. We store your subscription status, plan, trial and renewal dates and the identifiers needed to link your account with Stripe, the Apple App Store or Google Play. Payments are processed by those providers; we do not receive or store your full card number.

Settings and technical data. We store your language, voice and speech-to-text preferences and, if you choose ElevenLabs as your voice provider, the ElevenLabs API key and voice settings you provide. We also receive device and log information such as IP address, app version, operating system, and error and security logs.

Usage analytics. We may use privacy-friendly analytics (such as Google Analytics with anonymized data) to understand how the Service is used and to improve it.

3. How we use information

We use personal information to:

• provide, operate and secure the Service, including signing you in and keeping you signed in;
• generate AI-powered reply suggestions and convert text to speech in your chosen voice and language;
• personalize suggestions using your profile, memories and conversation context;
• manage your trial, subscription and billing;
• respond to your requests and provide support;
• monitor performance, fix bugs, prevent fraud and abuse, and protect our users;
• comply with legal obligations and enforce our Terms and Conditions.

We do not sell your personal information, we do not use it for third-party advertising, and we do not use your conversations to build advertising profiles.

4. AI and speech processing

To generate suggestions we send the relevant conversation context and profile information to Microsoft Azure OpenAI Service. To transcribe speech and synthesize voices we use Microsoft Azure Speech and, if you select it, ElevenLabs. These providers process data on our behalf to deliver the Service, under terms that restrict their use of that data to providing the service to us. If you use ElevenLabs with your own API key, the text to be spoken is also governed by your agreement with ElevenLabs.

AI-generated suggestions can be inaccurate or inappropriate. You decide what is spoken or sent, and you should review suggestions before using them.

5. Legal bases (EEA, UK and similar regions)

Where data protection law such as the GDPR applies, we rely on: performance of our contract with you (to provide the Service); your consent (for optional profile information, including health-related details, and microphone access, which you can withdraw at any time); our legitimate interests (securing and improving the Service); and compliance with legal obligations.

6. How we share information

We share personal information only as needed to run the Service:

• Service providers: cloud hosting and database providers, Microsoft Azure (AI, speech and storage), ElevenLabs (optional voices), analytics providers, and email or support tools;
• Sign-in providers: Google, Microsoft and Apple, to authenticate you;
• Payment and subscription providers: Stripe, Apple, Google and RevenueCat, to process and manage subscriptions;
• Legal and safety: when required by law or to protect the rights, safety and security of our users, the public or Cfluent;
• Business transfers: in connection with a merger, acquisition or sale of assets, subject to this policy.

We do not share your conversations or profile information with other Cfluent users.

7. Retention and deletion

We keep personal information while your account is active and as needed to provide the Service. Live meeting transcript fragments are kept only temporarily (they expire automatically after 24 hours and are deleted as soon as the meeting has been processed), and memories can expire automatically.

You can delete individual memories and conversations and you can delete your account from within the App. Deleting your account removes your user record and the data that belongs to you (such as profile, contacts, conversations, memories and uploaded content), cancels any active Stripe subscription, removes your customer record from RevenueCat and, for Apple sign-in, revokes the authorization. Subscriptions purchased through the App Store or Google Play must be canceled in your store account. Copies may remain in backups for a limited period and some information may be retained where required by law (for example, billing records).

8. Security

We use industry-standard safeguards, including encryption in transit (HTTPS/TLS), field-level encryption at rest for sensitive content such as conversation titles, summaries and memories, hashed refresh tokens, and access controls. No system is perfectly secure, so we cannot guarantee absolute security. If you believe your account has been compromised, contact us right away.

9. Your rights and choices

Depending on where you live, you may have the right to access, correct, delete, export or restrict the use of your personal information, to object to certain processing, to withdraw consent, and to lodge a complaint with your data protection authority. Residents of California and other US states may also have the right to know what personal information is collected, to request deletion and correction, and not to be discriminated against for exercising these rights; we do not sell or share personal information for cross-context behavioral advertising.

You can exercise most of these rights directly in the App (profile, memories, history and account deletion). For anything else, contact us using the details in section 14 and we will respond within the time required by law.

10. International transfers

Cfluent is operated from the United States and our providers may process data in the United States and other countries. Where required, we use appropriate safeguards, such as standard contractual clauses, for international transfers.

11. Children

Cfluent is intended for use by adults, or by minors under the supervision of a parent or legal guardian who creates and manages the account. We do not knowingly collect personal information directly from children under 13 without verifiable parental consent. If you believe a child has provided us information without consent, contact us and we will delete it.

12. The Website, cookies and local storage

The Website stores your language and display preferences in your browser (local storage or cookies) so the site shows in your language. The Website may also use basic analytics. You can clear or block this storage in your browser settings.

13. Changes to this policy

We may update this policy from time to time. We will post the new version on this page with a new "Last updated" date and, for material changes, notify you in the App or by email where appropriate.

14. Contact us

If you have questions or want to exercise your rights, contact us: