Privacy Policy
Effective as of 1st June 2024
This privacy policy describes how the developer (“we”, “us”, “our”) of the mobile application, Opul Personal Speech Assistant, collects, uses and protects your personal data.
Important Definitions
The following are terms that are frequently referred to in this privacy policy but not common in everyday language. We wanted to take a bit of extra time to explain them.
- Personal Data means any information that identifies or relates to a particular individual (often referred to as “personally identifiable information” or “PII”). Data that is completely anonymized and cannot be linked with an individual user is NOT considered Personal Data.
- Service Providers help us run our business and provide the Services to you. They may include:
- Hosting, analytics, database, and communication providers, such as the authentication service we use to allow you to log into your account.
- Support and customer service software providers, such as the software we use to communicate with you when you report a bug.
Summary
Whilst we hope you read this entire Privacy Policy, here is a brief overview of some important points:
- We don't and will not sell your data. (read more)
- We offer a free product and hope you'll purchase the paid product. That's how we make money. (read more)
- When you sign up for and use the mobile application, we process your account and—if applicable—payment information. (read more)
- To deliver the best possible experience to you, we and some of our service providers may process your text. Only we have visibility over your identity—our service providers have no way of linking your text to your identity. (read more)
- We also process some additional information, such as the type of device you're using. (read more)
- You can exercise your region-specific rights (like GDPR and CCPA rights). (read more)
How do we make money?
We offer a free and paid product, and we make money from subscriptions of the paid product. We don't, and never will, sell your data.
What data is collected and how do we collect it?
When you use the mobile application
| Category of Personal Data | Example | When we collect this data | Examples of why we collect this data |
|---|---|---|---|
| Profile or Contact Data | Name, Email | Directly from you, when you choose to give it to us (such as when you sign up for an account) | • So that you can log into your account • So that we can contact you |
| Device Data | Type of device and operating system used to access the Services | Automatically, when you use the mobile application | • To understand the range of devices the software should support • To debug software issues specific to certain devices or operating systems |
| Product Usage Data | Information on how you use and interact with the mobile application. For example, how often you use a specific feature. | Automatically, when you use the mobile application | • To understand feature usage and improve the product • Product Usage Data never includes the content you create in the mobile application |
When you reach out directly or otherwise choose to give us information
For instance, when you submit a bug report or request support, we'll collect the information you share with us to help solve your problem.
When you visit the website, opul.chat
We do NOT use cookies to track visitors to our website. We usevercel.com (the provider) for hosting, which includes basic analytical features to measure site traffic. The provider uses IP addresses to maintain unique visitor counts and location information derived from your IP address. However, they're contractually obligated not to collect any other personal information or sell your data.
When you choose to use certain features
When using specific features of the mobile application, certain data as detailed below will be sent to one or several of our Service Providers. Note, all data processed by our Service Providers (excluding Supabase) is anonymized, and therefore not classified as Personal Data and cannot be linked to your identity.
| Feature | Data Processed | When Data is Processed | Purpose of Processing | Service Provider & Location |
|---|---|---|---|---|
| Saved Phrases | Content of Phrase and associated fields | Save button is pressed in Save Phrase screen | So you can view and recall your Phrases on multiple devices | Supabase, AU region |
| Saved Topics | Content of Topic and associated fields | Save button is pressed in Save Topic screen | So you can view and recall your Topics on multiple devices | Supabase, AU region |
| Saved Places | Content of Place and associated fields | Save button is pressed in Save Place screen | So you can view and recall your Places on multiple devices | Supabase, AU region |
| Personality Traits | Options selected in Personality Traits | Save button is pressed within Personality Traits pages | When provided, your Personality Traits will be used to provide additional context for Smart Suggestions. | Supabase, AU region |
| Conversation Style | Options selected in Conversation Style | Save button is pressed within Conversation Style pages | When provided, your Conversation Style will be used to provide additional context for Smart Suggestions. | Supabase, AU region |
| Chats | Content of chat bar textfield (when you type to talk), time, day of week, system locale, place type (if location-based context is enabled) | Speak/send button in chat bar is pressed | Chat messages and supporting context are used to add more context to future conversations, making Smart Suggestions more relevant and personalised. | Supabase, AU region |
| Location-based context | Your Geo-coordinates | Location services is enabled | When enabled, smart suggestions will be given additional context in the form of the nearest place type. For example, “restaurant”, “cafe”, “airport”, etc. For the complete list of possible values,read more. | Google, no specific processing location |
| Smart Suggestions | Content of chat bar textfield, time, day of week, system locale, historical conversation metadata (topic, place type, day, time), place type (if location-based context is enabled), personality traits (if provided), conversation style (if provided), tone | Starters and Suggested phrases are loaded on home screen Suggestion button in chat bar is pressed | All context provided will be used to guide the output of LLM queries. | Groq, USA |
| ElevenLabs Text-to-Speech | Content of chat bar textfield | Speak button in chat bar is pressed | To provide you with spoken words | ElevenLabs, USA |
| Google text-to-speech | Content of chat bar textfield | Speak button in chat bar is pressed | To provide you with spoken words | Google, no specific processing location |
| OpenAI text-to-speech | Content of chat bar textfield | Speak button in chat bar is pressed | To provide you with spoken words | OpenAI, USA |
Under what conditions would we share your personal data?
We never sell your data, and we'll only share it in the following circumstances:
- With our Service Providers, as needed to provide and improve the product. Service Providers are contractually required to only handle your data in ways that we apecify, including being contractually prohibited from selling your data.
- If you ask us to. We'll share your data when you directly authorize it to be shared or share it yourself.
- If needed to meet our legal requirements or safety measures, or to enforce legal rights. See “Why do we collect personal data?” below for more.
Why do we collect personal data?
In general, we collect personal data to provide and improve the product and services. This includes data to make the mobile application work (such as account information) or data to make the mobile application better (such as Device or Product Usage Data). We also collect data to make sure we're able to:
- Protect against fraud, or implement additional security measures.
- Correspond with you if you reach out with a bug report, support request, or general inquiry. We may also send you updates, product information, or other marketing communications.
- Meet legal requirements, safety measures, and enforce legal rights. We're required to comply with any legal process, law, or regulation that requests we disclose personal information we've collected, so long as we consider the request reasonable and lawful. This includes:
- Enforcing our agreement terms or resolving disputes.
- Protecting your rights, property, or safety, or that of any party that interacts with our product.
How do we store and protect your data?
We use a combination of technical, physical, and logical safeguards to secure your data. These safeguards include encryption, secure network configuration, data transfer restrictions, restricted employee access, and several other measures.
We hold on to Personal Data for as long as you have an account with us or as otherwise necessary to provide you with the services. We'll only hang on to it for longer if needed to meet our legal requirements discussed above, or if it's anonymized so that it can't be linked to a specific user.
When it comes to user content, by default, we process user content associated with your account to provide services to you (for example, smart suggestions). After that, if you do not choose to retain that content, you can delete it, or delete your entire account, which will delete all personal data along with it.
How can I access, correct or delete my personal data?
You have a number of ways to interact with the personal data that we process, including requesting a record of your information, updating or correcting it, and deleting it.
- Request a personal data report. You can submit an access request for your data by submitting a support ticket to [email protected]
- Correct or update your data. You can update your name and email address through your Opul account settings.
- Stop us from processing your personal data. You can ask us to stop using your personal data for marketing emails by clicking “unsubscribe” on the emails you receive. In order to stop all processing of your personal data, you can delete your account through your Opul account settings.
- Delete your data. You can remove your personal data from Opul by deleting your account through your Opul account settings.
- Lodge a complaint. If you're based in the EEA, Switzerland, or the UK and think that we haven't complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.
Are there age limits to who can use the product?
As noted in the Beta User Agreement, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at [email protected]
Changes to this Privacy Policy
We're constantly trying to improve the product and services, so we may need to change this Privacy Policy from time to time. If we do, we'll let you know by placing a notice on the app and on the Opul website and/or contacting you directly, mostly likely via email.
If you opted not to receive legal notice emails, or you haven't given us your email in the first place, the updated policy will still apply. We'll do our best to get these updates in front of you, however, the ball's ultimately in your court to read and understand them. If you continue to use the product we'll assume the updates are good with you. Of course, give us a shout if there's anything that needs further explaining.
How can you contact us?
Email: [email protected]
If you are located in the EU or UK and have any questions or requests related to how we handle your data, please reach out via the email address above.