What Information Do We Collect?

Personal Information We Collect

When you browse our Website or use our App, we gather and utilize your personal information solely for the purposes outlined in this Policy. Personal information means any data about an individual, or any detail that could directly or indirectly identify a person.

We may obtain personal information directly from you, automatically as you interact with the Services, or generate it through certain actions—such as recording your interactions with us or collecting usage data from your device. This may include the following categories:

• Contract Management Information: Records of the Policy version you have acknowledged, your choices to accept or reject specific services or functionalities, the versions of service agreements you have agreed to or declined, along with the corresponding dates and times.
• Account Information: Your account credentials (such as email address), encrypted password, profile image, chosen nickname, country or region selected at registration, email verification code, and unique account identifier.
• Age Verification: We may request that you provide your age or other information to verify your eligibility for certain Services that is available for users with age restrictions. For users without full legal capacity, we may request a written consent of legal guardian.
• Order and Shipping Information: Details on your orders, including total and completed orders, payment amounts, dates of first and latest orders, order notes, and billing information (including first and last name, full name, company name, address, city, state code, postal code, state name, country code, country name, email, and phone number), as well as shipping addresses.
• Service Usage Information: Data such as IP address and activity logs generated while you interact with our Services (for example, clicks, search queries, access times, browsing records, and purchase activity).
• Review and Feedback Information: Information related to your product reviews (including your name, email, review title and content, uploaded photos, ratings history, and records of likes or dislikes), and any details you submit when using feedback features within the Services.
• Security & Analytics: We collect device and log data (such as MAC address, and IP) to detect fraud and improve services. Cookies are used for site functionality, security, and performance optimization.
• Customer Service Information: Data required to verify your identity (such as email and order number), logs of communications (including recorded calls), contact details (name, phone number, and address information needed for after-sales services), and other information necessary to address your inquiries.
• Voice-Related Data: means digital recordings of voices or audio segments collected or processed through the Services, including but not limited to My Voice Setup, Contact Voice Tagging. Voice-Related Data may also include incidental background audio captured during your use of the Services.

Personal Information Collected Automatically

When you access our Website or App, we may automatically collect personal information and other information from your devices using technologies such as cookies. Cookies are small text files sent by a website to your computer or other internet-connected device that help uniquely identify your browser or store specific information or preferences.

Mobile App Permissions

Optional permissions may be requested to enhance your experience with our services, including:

• Camera/Storage: To enable you to upload media when available.
• Location: To help match you with local advisors or resources.
• Microphone/Phone: To support voice calls with our support team.

You may revoke these permissions at any time through your device settings.

Third-Party SDKs

Certain features of our services may rely on external software development kits (SDKs) provided by third-party partners. While we carefully review and select these partners, the collection, use, and processing of data by such SDKs are governed by their respective independent privacy policies.

Contacts Function and Third-Party Personal Information

For information regarding the Contacts function and the processing of third-party personal information, including your obligations and responsibilities, please refer to Section 7(d) of our Terms of Use.

Voice-Related Data

When you use voice-based features, you represent that you have obtained any necessary consent from yourself and any individuals whose voices may be recorded or processed. You acknowledge and agree that audio data captured may be processed to enable identity recognition functions within the App, solely for the purposes described in this Privacy Policy. We rely on this consent and are not responsible for obtaining consent on your behalf. No biometric templates are created from these recordings. Voice recordings are only processed as needed to provide the requested features.

How Do We Use Your Information?

Subject to applicable laws, we process personal information for the purposes set out below, each relying on the relevant legal basis:

• Contract Management: We use contract management information to keep records of your acceptance or rejection of agreements, including contract and privacy notice versions, associated timestamps, and related decisions.
• Account Management: We process Account Information to facilitate activities such as creating, deleting, signing into, and updating your account.
• Personalization and Communications: We analyze your activity and preferences to recommend Services and offers that may interest you. With your consent, we may also send you marketing communications about platform updates, promotions, or partner offers. You can unsubscribe according to the instructions provided in the email.
• Security and Service Stability: Information such as your region, network operator, device model, operating system, app version, access source, access dates, browsing history, time spent, and interactive events is processed to identify suspicious activities, ensure the reliability and security of our Services, and support ongoing improvements. This is based on our legitimate interests, provided these do not override your rights or freedoms.
• Customer Service and Support: When you reach out through our online support channels or hotlines, we process certain Account Information and Customer Service Information, as well as any other details you provide, to manage troubleshooting, address complaints, and deliver general support. This processing is necessary to perform our contract with you.
• Investigations: We may use certain Account Information to fulfill our legal obligations (such as employment law requirements) or to pursue our legitimate interest in detecting and preventing fraud, provided your rights and freedoms are not adversely affected.
• Illegal Content Reporting: If you report unlawful content via our Services, we may collect and retain your name, email address, and any other details necessary to investigate and address the report, as required by law.
• Voice-related data: When you use voice-based features, we collect and process voice-related data to solely provide identity recognition function. This data is processed only for requested features and is not used for advertising, profiling, or AI training. We do not sell or share voice-related data with data brokers or other third parties. We will only process the information on the basis of your consent and/or entering into and performing our contract with you.

How Is Your Information Stored and Protected?

Your personal information is processed on servers located in the United States. We retain this information only for as long as necessary to achieve the purposes described in this Policy.

We will continue to process and store your personal information throughout the duration of our relationship with you. Typically, your personal information is associated with your account. When your account is deleted, any personal information linked to your account and related Services will be removed or anonymized, except where local regulations require us to retain it for a longer period.

To help safeguard your personal information from accidental or unlawful destruction, loss, modification, unauthorized disclosure, access, or other forms of improper handling, we have adopted suitable technical and organizational security measures in accordance with the law. You are responsible for keeping your account details confidential, including choosing a secure password and not sharing it with others. If you suspect that your account or personal information has been compromised—such as your password being disclosed without authorization—please contact us immediately using the information provided in this Policy.

Voice-related data is stored separately from other account information and encrypted both during network transmission and at rest. This data is retained only as long as necessary to provide the relevant features or as required by applicable law. When you delete your account or manually delete your voice-related data, all such recordings and associated text records are promptly removed, generally within 7 days, unless a longer retention period is required to fulfill the processing purpose or comply with applicable law.

Please note that the internet is an open network and transmitting information online is not entirely secure. Although we take reasonable steps to protect your personal information, we cannot guarantee the security of data sent to us over the internet. Any such transmission is at your own risk, and you are responsible for ensuring that any personal information you send is done so securely.

How Is Your Information Shared and Transferred Internationally?

Disclosure of Information

We may engage third-party service providers—including those offering IT solutions (such as cloud services), business operations support, payment processing, and customer service—to process your personal information on our behalf. These providers operate under contractual obligations to handle your personal information in accordance with our instructions. Additionally, we may share personal information with our affiliates for legitimate business reasons and to support the operation of the App, always in accordance with relevant laws and regulations.

Your personal information may also be disclosed under the following circumstances:

• Legal and Regulatory Compliance: To fulfill obligations under applicable laws, respond to legal proceedings, or comply with requests from regulatory authorities.
• Professional Advisors: To external auditors, legal counsel, or other professional consultants when their expertise is required.
• Business Transactions: To third parties as necessary in the event of a merger, acquisition, sale of assets, or if our services are transferred to another entity.
• For Affiliates and Subsidiaries: We may disclose your personal information among our affiliates and subsidiaries, for purposes consistent with this Privacy Policy.

Whenever we transfer or disclose your personal information, we do so in line with all applicable legal obligations and implement safeguards to ensure your information is adequately protected, providing a level of security equivalent to what is required in your jurisdiction.

Cross-Border Transfer of Information

Your personal information may be processed outside of your home country because of our servers located in the United States. For instance, users residing in Europe or Canada may have their personal information stored in the United States. Given the global nature of our operations, your personal information may also be accessed by our affiliates or shared with third-party customer support partners and SDK providers, in line with the purposes described in this Policy. This means your personal information might be transferred to jurisdictions that have different data protection laws and requirements than those in your country of residence. Data protection standards can vary significantly between regions, with some jurisdictions offering a higher level of protection than others. Regardless of where your personal information is processed, we will apply the safeguards described in this Policy.

If we transfer personal information internationally and such transfers are subject to legal requirements, we will put in place appropriate safeguards to ensure your information remains protected. These measures may include, where appropriate, relying on adequacy decisions that recognize the destination country as providing sufficient protection, using the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Agreement for transfers between our affiliates and relevant third parties (where applicable), or adopting any other lawful mechanism that allows the cross-border movement of personal information.

Aggregated Data

We may aggregate, anonymize, and/or de-identify information collected from or about you so that such information can no longer be used to identify you individually. Once information has been aggregated or de-identified, it is no longer considered personal information under applicable laws. We may use this aggregated or de-identified data for a variety of legally permissible purposes, including conducting research and analysis on customer demographics, interests, usage patterns, and behaviors in order to improve our services and inform business decisions. We may also share or disclose such aggregated or de-identified information with our affiliates, agents, business partners, research institutions, or other third parties for similar purposes, provided that such information does not identify any individual.

What Are Your Rights Regarding Your Personal Information?

Your Rights and Choices

Subject to applicable law, you may have the following rights and choices regarding your personal information:

• Right of Access: You have the ability to access your personal information associated with your account. For any additional requests to access your personal information, please reach out to us.
• Right to Rectification: You may update certain personal information linked to your account directly. For other correction requests concerning your personal information, please contact us.
• Right to Data Portability: You can request a copy of your personal information that you have provided to us, in a structured, commonly used, and machine-readable format, and, where applicable, request that we transfer it to another data controller.
• Right to Erasure: You can request the removal of all personal information related to your App account by deactivating your account. After deactivation, your personal information will be deleted. You may also request the deletion of certain personal information by contacting us. If we are unable to delete the information, we will inform you of the reasons why.
• Right to Withdraw Consent: If our processing of your personal information relies on your consent, you can withdraw your consent at any time by contacting us.
• Right to Object to Processing: Where permitted by law, you may object to our processing of your personal information based on legitimate interests, by contacting us and stating your specific circumstances. If we cannot comply with your objection, we will explain the reasons.
• Right to Restrict Processing: You may request that we limit the processing of your personal information in the following situations: (a) If processing is unlawful and you prefer restriction instead of deletion; (b) If you need us to retain your personal information for legal claims, even if we would otherwise delete it; (c) If you have disputed the accuracy of your personal information and verification is pending; (d) If you have objected to processing and a determination of overriding legitimate grounds is pending.

Other Rights

Depending on your location, you may have additional rights under local laws. For example, you may have the right to file a complaint with a relevant data protection authority if you believe we have violated data protection laws (such as the EU General Data Protection Regulation, the Australian Privacy Principles, or other registered APP codes in Australia).

Exercising Your Rights

To exercise any of these rights, ask questions, or submit a complaint regarding our processing of your personal information, please use the contact information provided in this Policy. When submitting a request, please clearly state the scope and legal basis for your request and provide enough information for us to verify your identity. We may request additional details to confirm your identity before responding to your request. We will address your request or complaint within the timeframes required by applicable data protection laws.

Notice to California Residents

This section applies solely to California residents and supplements our main Privacy Policy. It describes your rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) and explains how we handle your personal information.

• Collection and Use of Personal information. Within the past twelve (12) months, we have gathered personal information from and about you as detailed in Section 1 of this Policy.
• Disclosure of Personal information. Within the past twelve (12) months, we have shared personal information with third parties for business-related purposes. Specifically:
  • We have disclosed all categories of personal information listed in Section 1 of this Policy—except for certain operational data that remains cached only on the user’s device—to cloud storage service providers and our affiliated companies.
  • Information that is automatically collected or generated in connection with the use of our hotline services, such as communication records, your name, phone number, email address, and any other data you choose to provide to facilitate your request, has been shared with customer support service providers.
  • Audio files have been provided to our AI capability service provider to enable specific features.
  • Customer service-related information, as described in Section 1, has been shared with online customer service SDK providers to support your interactions with our support channels.
  • Our use of online advertising services may constitute “sharing” of your personal information under the CCPA, from which you have the right to opt out.
• Your CCPA Rights. If you are a California resident, you may have the right to exercise the following:
  • Right to Know – You may request details about the categories of personal information collected, the sources from which personal information is obtained, the business purposes for collecting, sharing, or selling personal information, and the third parties with whom we share personal information.
  • Right to Access – You may request a copy of the specific personal information we hold about you.
  • Right to Deletion – You may request the deletion of your personal information, subject to certain exceptions (such as fulfilling benefits, preventing fraud, or complying with legal obligations).
  • Right to Correction – You may request the correction of inaccurate personal information.
  • Right to Opt Out – You may opt out of the sale or sharing of your personal information (for example, for targeted advertising purposes).
  • Right to Nondiscrimination – You are entitled to exercise these rights without being subject to any form of penalty or discrimination.
• Limiting the Use of Sensitive Personal Information. You have the right to ask us to restrict how we use and disclose your sensitive personal information, except where certain exceptions under applicable law apply. If you wish to make this type of request, please contact us using the information provided in this Policy. We do not "sell" or "share" sensitive personal information, as these terms are defined by the CPRA.
• Do Not Sell or Share My Personal Information. Under the definitions of “sell” and “share” in the CPRA, we do not, and have not in the past twelve (12) months, sold or shared your personal information as those terms are defined by law.
• How to Submit California Consumer Rights Requests. You may exercise your California consumer rights by contacting us using the information provided in this Policy. Before we process your request, we will verify your identity, which may involve requesting additional personal information or asking you to log in to your account, where applicable. There may be instances where we are unable to fulfill or may limit your request, such as when we cannot confirm your identity, cannot locate your information, or are otherwise permitted by law to do so.
• Appeal. If your request is denied, you may appeal our decision by contacting us using the contact information provided in this Policy. If you are a California resident and your appeal is unsuccessful, you may file a complaint with the California Attorney General by following the instructions provided at: https://oag.ca.gov/contact/consumer-complaint-against-business-or-company.
• California’s “Shine the Light” Law. In accordance with California Civil Code Section 1798.83 (the “Shine the Light” law), California residents who have an established business relationship with us can request information about our sharing of personal information with third parties for their own direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.

Contact Information

If you have any concerns regarding potential security vulnerabilities, our privacy practices, or your data protection rights, or if you wish to contact our Data Protection Officer, you may do so using the contact details provided below:

Rymind Inc., with its mailing address located at 8 The Green, STE A #18650, Dover, Kent County, Delaware 19901, and email address at support-center@comulytic.ai.

Miscellaneous

Policy Update. We may update this Policy when necessary and encourage you to review the latest version by clicking the "Privacy Policy" link found in the footer of our website. If we make any significant changes to this Policy, we will notify you in advance—depending on the nature of the update—through methods such as pop-up notifications, push messages, emails, or other suitable channels.

Applicability of Terms of Use. The Terms of Use continue to govern all legal relationships arising from your use of our website and Services. In particular, the foregoing provisions relating to indemnification, release, and limitation of liability shall apply to any claims or disputes arising in connection with this Privacy Policy.

Dispute Resolution. Any dispute arising out of or relating to this Privacy Policy shall be resolved in accordance with the dispute resolution provisions set forth in our Terms of Use.