Privacy Policy – botTalk

A. Account and information you provide

• Email address, username, and authentication information. Passwords are protected using one-way hashing on our backend.
• Support requests and other communications you send us.
• Optional voice-enrollment information described in Section 5.
• Apple App Store subscription information. When you buy or restore a Premium subscription in the iOS app, Apple processes the payment. botTalk's server receives and keeps Apple's original transaction ID for the subscription, the product purchased, the subscription's status (including whether it is set to renew), and its dates, such as when it started and when it expires. The server also keeps a hashed account token, a one-way hash of your botTalk account identifier that is attached to the purchase so Apple's notifications about the subscription reach the right account. botTalk does not receive or store your payment-card number or other payment details, your Apple ID, or your App Store receipt.
• Google Play billing is not enabled as of this Policy's Effective Date. This Policy will be updated before botTalk begins processing Google Play purchase information.

B. Audio, transcripts, and AI requests

Microphone capture begins only when you start a feature that needs it and remains visibly disclosed by iOS or Android (for example, through the system microphone indicator) while microphone capture is active. The app analyzes short audio frames on your device for voice activity and, if you enabled enrolled-speaker filtering, whether speech matches your enrolled voice profile. Audio that is not selected by this process is not intentionally uploaded for transcription.

Selected speech is encoded as a WAV audio segment and uploaded over HTTPS to botTalk's authenticated backend, which runs on servers in Germany (Section 8). The backend holds the segment only while processing the request and forwards it through OpenRouter to the selected speech-recognition provider, which may be operated by OpenAI, Google (Gemini), or xAI. The resulting transcript, relevant instructions, and limited recent context are then sent through the same backend and AI gateway to generate the requested suggestion. The AI model providers that may process this information include OpenAI, Google (Gemini), and xAI. We disclose this so you know, before using the listening feature, that your selected speech audio, transcripts, and related request context may be sent to these third parties. Each provider processes that information under its own terms and privacy policy.

botTalk's backend does not create a server-side conversation-history archive from WAV audio, transcripts, prompts, or AI responses. It retains only the limited usage, allowance, accounting, security, and operational records described below. Completed transcript-and-suggestion history is encrypted and stored in the app's private storage on your device. It is not synchronized to your botTalk account or backed up by botTalk.

C. Technical and usage information

We process a pseudonymous installation credential, account identifier, request time and type, selected provider and model, audio duration or token counts, cost and allowance information, active-session information, and limited error, security, and fraud-prevention records. IP addresses may be used temporarily for rate limiting and may appear in limited infrastructure or proxy logs, but ordinary application request logs exclude IP addresses, headers, query strings, authentication information, request bodies, and identifying error details.

The Service does not request precise location. An IP address processed temporarily by network infrastructure may indicate an approximate region. We do not include a third-party behavioral analytics SDK.

D. Advertising (Google AdMob, Android app only)

This section applies only to the Android app. The iOS app does not currently display advertisements, and Google AdMob is not used in the iOS app. If botTalk begins showing advertisements in the iOS app, this Policy will be updated before it does.

The Android app displays advertisements, including rewarded advertisements that you may choose to watch to obtain additional daily usage, through Google AdMob. When an ad is requested or shown, AdMob and Google may collect and process device and usage information such as your IP address, device and operating-system information, the Android advertising ID, app and ad interaction data, and diagnostic information. Google may use this information to select and measure ads, which may include personalized ads, and to prevent fraud. Google's handling is governed by its own policies, including the Google Privacy Policy and the AdMob/Google Ads data-use disclosures.

You can reset or delete your Android advertising ID or opt out of ads personalization in your device settings. Where required by law, we request your consent before ad-related data is collected. We do not share conversation content, audio, transcripts, or voice profiles with AdMob or any advertiser.

We receive information directly from you, automatically from the app and its backend when you use the Service, from the Apple App Store when you buy or restore a subscription in the iOS app (including Apple's server notifications about that subscription), from Google AdMob for advertising in the Android app, and from service providers involved in authentication, email delivery, hosting, security, transcription, or AI generation. During optional voice enrollment, the speech-recognition service configured on your iOS or Android device may process enrollment audio to verify the words you read. Whether that processing occurs on your device or through a network service depends on your device and its settings.

• Provide voice-activity detection, optional enrolled-speaker filtering, transcription, and AI-generated suggestions requested by you.
• Create, authenticate, secure, and manage accounts, sessions, and subscriptions.
• Enforce usage limits and account for provider costs.
• Operate, secure, troubleshoot, and improve the reliability of the Service without creating a server-side archive of conversation content.
• Respond to support requests and communicate administrative or security information about the Service.
• Prevent, investigate, and respond to fraud, abuse, security threats, and violations of our Terms.
• Comply with legal obligations and establish, exercise, or defend legal claims.

We do not use conversation content or voice profiles for advertising, and we do not sell personal information.

We do not sell personal information. We disclose information only as described below:

• AI processing. OpenRouter and the selected downstream AI provider, which may be OpenAI, Google (Gemini), or xAI, receive selected WAV audio when required for transcription. They also receive transcripts, instructions, and limited recent context needed to generate a response. The selected provider or model is displayed through the Service. Provider practices may vary.
• OpenRouter privacy controls. botTalk configures its OpenRouter requests to deny routing to providers that collect request data for model training or related data-collection purposes. This setting is different from Zero Data Retention. Unless a request is routed to a provider endpoint with a Zero Data Retention policy, a downstream provider may retain request information under its published policy.
• Device speech recognition. During optional enrollment, the speech-recognition service configured on your iOS or Android device may receive enrollment audio to verify the words you read.
• Hosting and operations. Hetzner Online GmbH hosts botTalk's backend servers in Germany and holds the information stored on them on botTalk's behalf. Cloudflare, Inc. hosts the bot-talk.app website. Brevo (Sendinblue SAS) sends password-reset and account-deletion emails, and Zoho hosts the [email protected] mailbox. Network and security providers process limited information as needed to operate the Service on botTalk's behalf. Section 8 lists the recipients that receive information outside your country.
• Advertising. In the Android app, Google AdMob receives the device and ad-interaction information described in Section 1.D to serve and measure advertisements. It does not receive conversation content, audio, transcripts, or voice profiles.
• Payments. The Apple App Store processes subscriptions bought in the iOS app and provides botTalk with the subscription information described in Section 1.A. botTalk gives Apple the hashed account token described there so the purchase can be linked to your account. Apple's handling is governed by its own policies. Google Play billing is not enabled as of this Policy's Effective Date.
• Legal and safety. We may disclose information when reasonably necessary to comply with applicable law or legal process; enforce our agreements; investigate fraud, abuse, or security incidents; or protect botTalk, users, or others.
• Business transfers. Information may be transferred as part of a merger, financing, reorganization, acquisition, bankruptcy, or sale of assets, subject to applicable law and the protections described in this Policy.

You are responsible for obtaining any legally required consent from another person before intentionally using the Service to capture or process that person's voice or conversation.

Voice enrollment is optional. You may select "Continue without speech enrollment" and still use the Service's main functions. If you enroll, botTalk creates a numeric voice profile, which is biometric data, used to determine whether detected speech likely matches the enrolled speaker for the optional speaker-filter feature.

The encrypted local copy is stored in app-private storage. An account-linked encrypted copy is stored on botTalk's servers in Germany (Section 8) so the profile can be restored for the same account. botTalk does not use the profile to verify a government-issued or civil identity, for advertising, or to train an AI model. We treat the voice profile as biometric data (a voiceprint used for speaker recognition) and as sensitive personal information. We do not sell, lease, or trade it, and we do not disclose it to advertisers, AdMob, or the AI providers listed in Section 4. We retain it only for the limited period stated in Section 6: until you delete it or your account, and in any event no longer than 3 years after your voice enrollment began, after which it is permanently deleted.

Where processing requires consent, enrollment occurs only after you make the separate choice to enroll. Refusing enrollment does not prevent access to the Service's main functions. You may withdraw consent and stop future use of the profile at any time by deleting the voice profile through the app's privacy or voice settings, or by contacting [email protected]. Deleting the voice profile disables enrolled-speaker filtering and deletes the account-linked backend profile and local profile, subject to the backup expiration period in Section 6. Withdrawal does not affect processing that was lawful before withdrawal.

Re-enrollment replaces the existing profile. Permanently deleting your account also deletes the account-linked backend profile and instructs the app to delete the local profile.

botTalk keeps personal information only for the periods stated below or for the shortest longer period required by applicable law. Automated retention jobs run hourly using bounded deletion batches.

WAV audio, transcripts, prompts, and AI responses. botTalk's backend holds this content only while completing the provider request and does not retain it afterward as server-side conversation history. OpenRouter and downstream providers control their own processing and retention, subject to the privacy controls and provider policies described in Section 4.

On-device conversation history. Encrypted history remains in the app's private storage until you clear it, permanently delete the account through the app, clear app storage, or uninstall the app.

Password reset and verification. Password-reset codes and verification records are deleted within 24 hours after expiration. Password-reset delivery and abuse-prevention records are deleted within 7 days.

Sessions and installation credentials. Active credentials are retained while necessary to authenticate an authorized account or installation. Expired or revoked application sessions are deleted within 30 days after expiration or revocation.

Request reservations and usage records. Abandoned reservations are safely reclaimed after they can no longer represent a live request. Completed request reservations and daily usage or allowance records are ordinarily deleted within 30 days.

Accounting and Premium records. Minimal account-linked accounting records and Premium allowance-period records are deleted within 395 days.

App Store subscription records. The original transaction ID, product, status, and dates are kept while the subscription is active or in a billing-retry or grace period, and for 60 days after Premium access from that subscription ends, and are then deleted. If you later restore the purchase, the record is created again. The hashed account token is kept for the life of the account. Permanently deleting your account deletes both immediately but does not cancel the subscription with Apple; manage or cancel it in your Apple account settings. Apple keeps its own purchase records under its own policies.

Logs. Ordinary application request logging is disabled. Application request logs exclude request bodies, authentication information, IP addresses, headers, query strings, and identifying error details. IP addresses used for rate limiting are ordinarily held only in memory for the applicable rate-limit window. Infrastructure and proxy logs are retained for no longer than 30 days, and container logs are subject to capped rotation.

Security and fraud records. These records are ordinarily deleted or irreversibly de-identified within 30 days. A hold may preserve only records tied to a specific account, device, or request when reasonably necessary to investigate an active incident. Each hold is reviewed at least every 30 days and ends no later than one year after it begins, unless a separate legal preservation obligation requires otherwise.

Support communications. These are ordinarily deleted within 12 months after the support matter is closed.

Account information and voice profiles. Account information is retained for the lifetime of the account and deleted when the account is permanently deleted. Voice profiles (biometric data). The server-side voice profile is retained only until you delete the voice profile, you permanently delete your account, or 3 years have passed since your voice enrollment began, whichever occurs first, at which point it is permanently deleted. The local voice profile is deleted when you delete it, clear app storage, or uninstall the app.

Backups. Backups containing deleted account or voice-profile information expire within 30 days. Deleted information may remain in encrypted backups until expiration but is not restored into active service except when necessary for disaster recovery; if restored, the applicable deletion is re-applied.

Retention-run records. botTalk may retain aggregate records showing that a retention job ran. These records do not contain customer identifiers.

Depending on where you live, applicable law may give you rights concerning personal information. You may submit a request to [email protected]. We may request information reasonably necessary to verify your identity or authority. Where required, we will respond without undue delay and ordinarily within one month, or sooner where Sections 9 through 12 state a shorter period. Rights may be subject to exceptions under applicable law.

• Access: request confirmation of whether we process your personal information and receive a copy of personal information within the scope of the applicable right.
• Correction: request correction of inaccurate or incomplete personal information.
• Erasure or deletion: request deletion where the applicable legal conditions are met. This is sometimes called the right to erasure or right to be forgotten.
• Restriction: request that certain processing be restricted in circumstances provided by law.
• Data portability: where applicable, receive personal information you provided to us in a structured, commonly used, machine-readable format and request transmission to another controller where technically feasible.
• Objection: object to processing based on legitimate interests in circumstances provided by law. botTalk does not use your personal information for direct marketing; advertising data collected by Google AdMob in the Android app is described in Section 1.D, and you may limit it as described there.
• Withdraw consent: withdraw consent at any time for processing based on consent, including optional voice-profile processing, without affecting the lawfulness of earlier processing.
• Complaint: lodge a complaint with an applicable privacy or data-protection regulator. Sections 9 through 12 identify the regulators for South Africa, Brazil, India, and South Korea.

Requests may be submitted by email. When portability applies, botTalk will provide eligible server-held data electronically. Conversation history is stored locally on your device and is not available from botTalk's servers. The app may be used to view, clear, or export locally stored history where an export feature is available.

Uninstalling botTalk or clearing app storage permanently deletes local history and the local voice profile. Reinstalling or signing in again cannot restore local history. Uninstalling alone does not delete the online account or backend voice profile.

Where botTalk's servers are. botTalk's backend servers, including api.bot-talk.app, are located in Germany and operated by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. Hetzner provides the server hardware, data centers, and network as botTalk's hosting provider. botTalk administers the software and data on those servers from the United States. The account, voice-profile, subscription, usage, accounting, and security records described in Section 6 are stored on these servers, and selected audio and AI requests pass through them while being processed.

How information is sent. The app sends information to botTalk's servers in Germany over encrypted HTTPS connections. When you request a transcription or AI suggestion, botTalk's servers send the request over encrypted connections to OpenRouter in the United States, which routes it to the selected AI provider. Password-reset and account-deletion emails are sent through Brevo, and support emails are kept in a Zoho mailbox. The bot-talk.app website is served by Cloudflare. Advertising data in the Android app is collected directly by Google AdMob.

Recipients outside your country. Depending on where you live, the recipients below may be in a country whose data-protection laws differ from the laws where you live. For each recipient, this list states its country, contact information, the information it receives, when and how it receives it, its purpose, and how long it keeps the information. Sections 9 through 12 describe the legal mechanisms botTalk relies on for transfers from South Africa, Brazil, India, and South Korea. Where another applicable data-transfer law requires safeguards for a transfer made by botTalk, botTalk will use a mechanism recognized by that law and will provide information about it upon request.

Provider-by-provider privacy and retention information for OpenRouter-routed requests is available in the OpenRouter provider logging and retention directory.

This section applies if you are located in the Republic of South Africa. It supplements the rest of this Policy and describes how botTalk processes personal information under the Protection of Personal Information Act 4 of 2013 ("POPIA"). If this section conflicts with another part of this Policy for South African residents, this section governs.

Responsible party and Information Officer. For purposes of POPIA, the responsible party is Giovanni Gutierrez, operating botTalk from Utah, United States, who also acts as botTalk's Information Officer. You can reach the Information Officer at [email protected].

What we process and why. botTalk processes the personal information described in Section 1, obtained from the sources described in Section 2, for the purposes described in Section 3. It is shared only with the recipients described in Section 4 and retained only for the periods described in Section 6. botTalk relies on the following grounds under section 11 of POPIA:

• Contract: processing necessary to create your account, provide the features you request, including transcription and AI-generated suggestions, and provide any Premium subscription you buy.
• Legitimate interests: securing the Service, preventing fraud and abuse, enforcing usage limits, maintaining reliability, and displaying advertisements in the Android app that support free usage, subject to your choices described in Section 1.D.
• Legal obligation: complying with obligations imposed on botTalk by law.
• Consent: optional voice enrollment and, where consent is required, ad-related data collection in the Android app.

Mandatory and voluntary information. An email address, username, and password are required to create an account; without them, botTalk cannot provide the Service. Microphone access is required to use the listening feature. Voice enrollment is voluntary, and declining it does not prevent use of the Service's main functions. You may limit personalized advertising as described in Section 1.D.

Special personal information. POPIA treats biometric information as special personal information. botTalk processes the voice profile described in Section 5 only with the consent you give when you choose to enroll, and only for optional enrolled-speaker filtering. You may withdraw that consent at any time by deleting the voice profile as described in Section 5. botTalk does not intentionally collect other special personal information. If you discuss sensitive topics, such as health or religious beliefs, while using the listening feature, that content is processed at your direction only as described in Section 1.B and is not kept as server-side conversation history.

Children. POPIA defines a child as a person under 18. botTalk does not knowingly process the personal information of a child in South Africa without the prior consent of a competent person, such as a parent or guardian. If you are under 18 and located in South Africa, you may use the Service only with that consent. If we learn that a child's personal information was processed without the required consent, we will delete it.

Transfers outside South Africa. botTalk's servers are in Germany and botTalk is operated from the United States, so personal information collected from you in South Africa is transferred to Germany and the United States and may be processed in other countries as described in Section 8. botTalk makes these transfers under section 72 of POPIA because they are necessary to perform its agreement with you to provide the Service you request. For optional processing, including the account-linked voice profile, botTalk also relies on your consent.

Your rights under POPIA. In addition to the rights described in Section 7, you have the right to:

• Request confirmation, free of charge, of whether botTalk holds personal information about you, and request a record or description of that information, including the identity or categories of third parties that have had access to it.
• Request correction, destruction, or deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or unlawfully obtained, or that botTalk is no longer authorized to retain.
• Object, on reasonable grounds relating to your particular situation, to processing based on legitimate interests, and object at any time to processing for direct marketing. botTalk does not send unsolicited electronic direct marketing.
• Not be subject to a decision that has legal consequences for you, or affects you to a substantial degree, based solely on automated processing intended to profile you. botTalk does not make such decisions; enrolled-speaker filtering and AI-generated suggestions do not produce legal or similarly significant effects.
• Withdraw consent at any time, without affecting processing that occurred before withdrawal.
• Lodge a complaint with the Information Regulator and institute civil proceedings regarding an alleged interference with the protection of your personal information.

Submit requests to [email protected]. We may request information reasonably necessary to verify your identity before acting on a request.

Security compromises. If botTalk has reasonable grounds to believe that your personal information has been accessed or acquired by an unauthorized person, botTalk will notify the Information Regulator and you as soon as reasonably possible after discovering the compromise, as required by section 22 of POPIA, unless a public body responsible for investigating offences or the Information Regulator determines that notification would impede a criminal investigation.

Information Regulator. We encourage you to contact us first so we can try to resolve your concern, but you may contact South Africa's Information Regulator at any time:

• Website: inforegulator.org.za
• POPIA complaints: [email protected]
• General enquiries: [email protected]
• Telephone: +27 10 023 5200 or toll-free 0800 017 160 within South Africa
• Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191, South Africa

This section applies when Brazil's General Personal Data Protection Law (Lei nº 13.709/2018, the "LGPD") applies to botTalk's processing of your personal data, including when you use the Service in Brazil. It supplements the rest of this Policy. If this section conflicts with another part of this Policy for processing subject to the LGPD, this section governs.

Controller and encarregado. The controller (controlador) is Giovanni Gutierrez, operating botTalk from Utah, United States. Giovanni Gutierrez is also botTalk's data protection officer (encarregado pelo tratamento de dados pessoais) under Article 41 of the LGPD. You can reach the encarregado at [email protected].

Legal bases. botTalk processes the personal data described in Section 1 for the purposes described in Section 3 on the following legal bases under Article 7 of the LGPD:

• Performance of a contract (Article 7, V): creating and managing your account, providing the transcription and AI-generated suggestions you request, and providing any Premium subscription you buy.
• Legitimate interests (Article 7, IX): securing the Service, preventing fraud and abuse, enforcing usage limits, maintaining reliability, and displaying advertisements in the Android app that support free usage, subject to your choices described in Section 1.D and to your fundamental rights and freedoms.
• Compliance with a legal or regulatory obligation (Article 7, II).
• Regular exercise of rights in judicial, administrative, or arbitral proceedings (Article 7, VI).
• Consent (Article 7, I): ad-related data collection in the Android app where consent is required.

Sensitive personal data. Under the LGPD, biometric data is sensitive personal data. botTalk processes the voice profile described in Section 5 only on the basis of your specific and highlighted consent (Article 11, I), which you give through the separate enrollment choice in the app, and only for optional enrolled-speaker filtering. botTalk does not use the profile to verify your identity, for advertising, or to train AI models. You may revoke that consent at any time, free of charge, by deleting the voice profile as described in Section 5. botTalk does not intentionally collect other sensitive personal data. If you discuss sensitive topics, such as health or religious beliefs, while using the listening feature, that content is processed at your direction only as described in Section 1.B and is not kept as server-side conversation history.

Refusing consent. You may refuse voice enrollment and still use the Service's main functions; the only consequence is that enrolled-speaker filtering is unavailable. Your email address, username, and password are needed to create an account, and microphone access is needed to use the listening feature; without them, botTalk cannot provide those parts of the Service. You may limit personalized advertising as described in Section 1.D.

Your rights under Article 18 of the LGPD. You may request from botTalk, free of charge:

• Confirmation of whether botTalk processes your personal data.
• Access to your personal data.
• Correction of incomplete, inaccurate, or out-of-date data.
• Anonymization, blocking, or deletion of unnecessary or excessive data, or of data processed in violation of the LGPD.
• Portability of your data to another service or product provider, upon express request, in accordance with the regulations of the national authority.
• Deletion of personal data processed with your consent, except where Article 16 of the LGPD permits it to be kept.
• Information about the public and private entities with which botTalk has shared your data. They are listed in Sections 4 and 8.
• Information about the possibility of not giving consent and the consequences of refusing, as described above.
• Revocation of your consent at any time.

You may also request review of decisions made solely on the basis of automated processing that affect your interests (Article 20). botTalk does not use automated decisions to define your personal, professional, consumer, or credit profile or aspects of your personality.

How to exercise your rights. Send your request to the encarregado at [email protected]. We may ask for information reasonably necessary to verify your identity. Requests for confirmation of processing or access will be answered immediately in simplified form or, if you ask for a clear and complete statement, within 15 days of your request (Article 19). If we cannot act on a request immediately, we will tell you why. When we correct, delete, anonymize, or block your data, we will inform the entities with which we shared it so they can do the same, unless that is impossible or requires disproportionate effort.

How your data is sent abroad. botTalk's servers are in Germany and botTalk is operated from the United States, so personal data collected from you in Brazil is sent outside Brazil. The app sends your data over encrypted HTTPS connections to botTalk's servers in Germany, operated by Hetzner Online GmbH. When you request a transcription or AI suggestion, those servers send the request over encrypted connections to OpenRouter and the selected AI provider in the United States. Section 8 lists every recipient, its country, the data it receives, why, and for how long. To the extent these are international transfers under the LGPD, botTalk relies on Article 33:

• Transfers necessary to perform the contract with you and provide the Service you request, such as hosting your account in Germany and sending your requests to AI providers: Article 33, IX, with Article 7, V.
• Storage of the account-linked voice profile on botTalk's servers in Germany: your specific and highlighted consent, given when you choose to enroll after being informed that the profile is stored outside Brazil (Article 33, VIII).
• Transfers needed to comply with a legal obligation or to exercise rights in proceedings: Article 33, IX, with Article 7, II and VI.

Security incidents. If a security incident may create a relevant risk or damage to you, botTalk will notify you and the ANPD within the period set by ANPD regulations (Article 48).

Children and adolescents. botTalk processes personal data of children and adolescents only in their best interest (Article 14). The Service is not directed to children under 13 (Section 14). If you are under 18 and located in Brazil, you may use the Service only with the permission of a parent or legal guardian.

Complaints to the ANPD. If you are not satisfied with our response, you may petition Brazil's National Data Protection Authority (Autoridade Nacional de Proteção de Dados, "ANPD") regarding your data (Article 18, §1) at gov.br/anpd. The ANPD may ask you to show that you first submitted your request to botTalk and that it was not resolved. You may also exercise this right before consumer protection bodies (Article 18, §8).

This section applies if you are located in India. It describes how botTalk processes your digital personal data under the Digital Personal Data Protection Act, 2023 (the "DPDP Act") and the Digital Personal Data Protection Rules, 2025, as their provisions come into force, and under the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the "SPDI Rules") while they apply. It supplements the rest of this Policy. If this section conflicts with another part of this Policy for users in India, this section governs.

Data Fiduciary. Giovanni Gutierrez, operating botTalk from Utah, United States, is the Data Fiduciary for your personal data.

Grievance Officer. botTalk's Grievance Officer, who can also answer questions about the processing of your personal data on botTalk's behalf, is:

• Name: Giovanni Gutierrez
• Email: [email protected]

The Grievance Officer will resolve your grievance within one month of receiving it.

What we process and why. botTalk processes the following personal data for the following purposes:

• Email address, username, and password (stored as a one-way hash): to create, authenticate, and secure your account.
• Selected speech audio, transcripts, instructions, and limited recent context: to transcribe your speech and generate the AI suggestions you request. This content is not kept as server-side conversation history (Section 1.B).
• Voice profile (optional, with your consent): only for enrolled-speaker filtering (Section 5).
• App Store subscription information and the hashed account token (iOS app): to provide and manage Premium subscriptions (Section 1.A).
• Installation, session, usage, allowance, accounting, security, and limited log data: to enforce usage limits, account for costs, and secure the Service (Section 1.C).
• Advertising data collected by Google AdMob (Android app): to show and measure ads, including rewarded ads (Section 1.D).
• Support communications: to respond to your requests.

botTalk processes this personal data on the basis of the consent you give in the app and, where the DPDP Act permits, for legitimate uses under its section 7, such as personal data you voluntarily provide for a specified purpose and processing required to comply with law. Your password and voice profile are sensitive personal data or information under the SPDI Rules; botTalk collects them only with the consent you give in the app, and only for the purposes stated above.

How to withdraw consent. You may withdraw your consent at any time, as easily as you gave it:

• Voice profile: delete it under Settings → Audio & voice in the app (Section 5).
• Your account and other consent-based processing: delete your account with Delete Account in the app or at bot-talk.app/delete-account (Section 16).
• Personalized ads in the Android app: opt out of ads personalization or delete your advertising ID in your device settings (Section 1.D).
• Any processing: email the Grievance Officer at [email protected].

After you withdraw consent, botTalk will, within a reasonable time, stop processing the affected personal data and cause its processors to stop, unless processing without your consent is required or authorized by law. Withdrawal does not affect processing that happened before it. If you withdraw consent to processing the Service needs, such as your account information or sending your requests to AI providers, botTalk will be unable to provide the Service.

Brevo, Zoho, and Google AdMob. Brevo (Sendinblue SAS), which sends password-reset and account-deletion emails, and Zoho, which hosts the support mailbox, process personal data as botTalk's Data Processors, and botTalk remains responsible for that processing under the DPDP Act. Google, which is not affiliated with botTalk, decides how it processes the advertising data it collects through AdMob in the Android app (Section 1.D) and is responsible for its own compliance with Indian law, including the DPDP Act, for that processing.

Your rights. Subject to the DPDP Act, you have the right to:

• Obtain a summary of the personal data botTalk processes about you and the related processing activities, and the identities of the other Data Fiduciaries and Data Processors with which it has been shared, with a description of the data shared. Sections 4 and 8 list them.
• Correction, completion, updating, and erasure of your personal data.
• Have your grievances addressed by the Grievance Officer.
• Nominate another individual to exercise your rights if you die or become incapacitated. To nominate someone, email the Grievance Officer.

Submit requests to [email protected]. We may request information reasonably necessary to verify your identity.

Complaints to the Data Protection Board of India. If the Grievance Officer does not resolve your grievance to your satisfaction, or does not respond within the time stated above, you may file a complaint with the Data Protection Board of India through the digital means the Board makes available. Under section 13(3) of the DPDP Act, you must first use botTalk's grievance redressal mechanism before approaching the Board.

Transfers outside India. botTalk's servers are in Germany and the other recipients listed in Section 8 are mainly in the United States, so personal data collected from you in India is transferred outside India. botTalk makes these transfers because they are necessary to perform its agreement with you or because you have consented, and will not transfer personal data to any country or territory that the Central Government of India restricts by notification under section 16 of the DPDP Act.

Children. Under the DPDP Act, a child is a person under 18. If you are under 18 and located in India, you may use the Service only with the verifiable consent of your parent or lawful guardian. If we learn that we processed a child's personal data without that consent, we will delete it.

Personal data breaches. If a personal data breach occurs, botTalk will notify the Data Protection Board of India and affected Data Principals as required by the DPDP Act and the Digital Personal Data Protection Rules, 2025.

This section applies if you are located in the Republic of Korea. Together with the rest of this Policy, it is botTalk's privacy policy under the Personal Information Protection Act ("PIPA"). If this section conflicts with another part of this Policy for users in Korea, this section governs. A Korean version of this Policy is available at bot-talk.app/privacy-policy/ko (개인정보 처리방침).

Chief Privacy Officer. botTalk's Chief Privacy Officer, who is also responsible for receiving and handling requests to access personal information, is:

• Name: Giovanni Gutierrez
• Email: [email protected]

Items, purposes, and retention. The personal information botTalk processes is described in Section 1, its purposes in Section 3, and how long it is kept in Section 6. botTalk processes personal information only within the scope of those purposes.

Sensitive information. A voice profile used to recognize a specific person is sensitive information under PIPA. botTalk creates it only with the separate consent you give when you choose to enroll (Section 5).

Third-party provision and outsourcing. botTalk provides personal information to others only as described in Section 4. Hetzner Online GmbH (server hosting), Cloudflare, Inc. (website hosting), Sendinblue SAS, doing business as Brevo (account emails), Zoho Corporation (support mailbox), OpenRouter, Inc. (AI request routing), and the AI providers OpenAI, Google, and xAI (transcription and AI suggestions) process personal information to perform work botTalk entrusts to them. Apple Inc. and Google LLC (AdMob) receive the information described in Section 8 for their own App Store and advertising services.

Cross-border transfers. All of the recipients above are outside Korea. For each transfer, Section 8 lists the recipient and its contact information, the country, the personal information transferred, when and how it is transferred, the recipient's purpose, and how long the recipient keeps it. Transfers needed to provide the Service are made because they are necessary to conclude and perform the contract with you and are disclosed in this Policy (PIPA Article 28-8(1)(3)). Storage of the voice profile on botTalk's servers in Germany is based on your separate consent at enrollment.

Refusing cross-border transfers. You can refuse these transfers by not using the Service, deleting the voice profile (Section 5), deleting your account (Section 16), limiting personalized ads in your Android settings (Section 1.D), or contacting the Chief Privacy Officer. Because botTalk's servers are in Germany and transcription and AI suggestions are provided by AI providers outside Korea, refusing those transfers means botTalk cannot provide the Service. Refusing voice enrollment only disables enrolled-speaker filtering.

Destruction of personal information. When a retention period in Section 6 ends or the purpose of processing is achieved, botTalk destroys the personal information without delay. Electronic records are permanently deleted from active systems by automated retention jobs, and remaining copies in encrypted backups expire as described in Section 6. botTalk does not keep paper records of your personal information. If applicable law requires botTalk to keep personal information longer, it is stored separately from other personal information and kept only for the required period.

Safety measures. botTalk takes the measures described in Section 15, including administrative measures, such as limiting access to personal information to operational need; technical measures, such as encrypted network connections, one-way password hashing, encryption of voice profiles and on-device history, access controls, and rate limiting; and physical measures, through the access-controlled data centers in Germany where Hetzner houses botTalk's servers.

Automatic collection of information. botTalk's website does not use cookies for analytics or advertising, and botTalk does not include a third-party behavioral analytics SDK in its apps. The Android app includes Google AdMob, which uses the Android advertising ID and ad-interaction data (behavioral information) to show and measure ads, which may be personalized. You can refuse this by opting out of ads personalization or deleting your advertising ID in your Android settings. The iOS app does not show ads.

Your rights. You, or your legal representative or a person you authorize, may request access to, correction or deletion of, or suspension of processing of your personal information, and may withdraw consent, by emailing the Chief Privacy Officer at [email protected]. A request made through an authorized person must include a power of attorney. botTalk will respond within 10 days of receiving your request. If botTalk cannot fulfil a request in whole or in part because of an exception under PIPA, it will tell you the reason and how to object. botTalk does not make automated decisions that significantly affect your rights or obligations.

Children under 14. If you are under 14 and located in Korea, you may use the Service only with the consent of your legal representative. If botTalk learns that it collected personal information of a child under 14 without that consent, it will delete it.

Remedies. You can contact the Chief Privacy Officer about any privacy concern. Under PIPA, you can also report an infringement of your personal information to the Personal Information Protection Commission (PIPC), which has designated the Korea Internet & Security Agency's Personal Information Infringement Report Center to receive reports, or apply for dispute mediation or consultation from the following bodies:

• Personal Information Protection Commission (PIPC): www.pipc.go.kr
• Personal Information Infringement Report Center: privacy.kisa.or.kr, telephone 118
• Personal Information Dispute Mediation Committee: www.kopico.go.kr, telephone 1833-6972
• Supreme Prosecutors' Office: www.spo.go.kr, telephone 1301
• Korean National Police Agency Cyber Bureau: ecrm.police.go.kr, telephone 182

botTalk does not make the Service available in the European Economic Area, the United Kingdom, Switzerland, or mainland China. Do not create an account or use the Service while you are located in any of those places. The Terms of Service contain the same restriction.

The Service is not directed to children under 13. Where local law sets a higher age for a child to consent to relevant data processing, the applicable higher age applies. If you are under 18, you represent that you have permission from a parent or guardian where required. We do not knowingly collect personal information from a child in violation of applicable law. If we learn that we have done so, we will delete the information as required.

We use reasonable technical and organizational safeguards appropriate to the nature of the information and the risks presented. Network requests use encrypted transport. Local conversation records and the local voice profile are encrypted in app-private storage. Server-side voice profiles are encrypted. Access is limited according to operational need. Retention jobs use bounded, transactional deletion batches, and retention holds are limited and periodically reviewed.

No security measure can guarantee absolute security, and third-party providers remain responsible for their own systems. If a personal-data breach requires notice under applicable law, botTalk will notify the appropriate authority and affected individuals as required.

Clearing history deletes the local conversation history but does not delete the online account. Uninstalling or clearing app storage deletes local data but does not, by itself, delete the online account or server-side voice profile.

You may permanently delete your account through the app or permanently delete your voice profile under Settings → Audio & voice. Deletion removes the encrypted copies and disables speaker filtering. Re-enrollment replaces any existing profile. Successful account deletion via "Delete Account" removes the account profile and account-linked voice profile from active systems controlled by botTalk and instructs the app to delete that account's local history. Limited information may remain temporarily in encrypted backups or be retained where applicable law permits or requires it, subject to Section 6.

The Last Updated date identifies when this text was most recently revised. The Effective Date identifies when this version begins governing the processing described in it; it is the same for the version of the Policy and does not depend on when a particular user downloaded the app or created an account.

We may revise this Policy as the Service or applicable law changes. For new users, the then-current version applies when they begin using the Service. For existing users, material changes will take effect on the stated Effective Date after advance notice through the app or email when required or practicable. If a change requires new consent, botTalk will request that consent instead of treating continued use as consent.