Parlay Legal Documentation

Privacy Policy

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

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Introduction

Welcome to Parlay. We respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, share, and protect your information when you use the Parlay mobile application and related services (the "Service").

**By using Parlay, you agree to this Privacy Policy.** If you don't agree, please don't use Parlay.

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## Quick Summary

Here's what you need to know:

* ✅ We collect your account info, recordings, and usage data
* ✅ We use AI to analyze your recordings (OpenAI, Anthropic, Google)
* ✅ We don't sell your personal information
* ✅ We use your data to provide the Service and improve AI
* ✅ You can delete your account and data anytime
* ✅ We implement security measures but can't guarantee 100% security
* ✅ Your data is stored in the United States

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## 1. Information We Collect

### Information You Provide

**Account Information:**

* Name
* Email address
* Phone number (for phone-based login)
* Password (encrypted)
* Profile picture (optional)
* Organization information (if applicable)

**Content You Create:**

* **Audio recordings** of your pitches, presentations, and practice sessions
* **Transcriptions** generated from your recordings
* **Text content** including comments, feedback, playlist names, and notes
* **Practice session details** including pitch type, title, and context

**Communications:**

* Support requests and correspondence
* Feedback and suggestions
* Survey responses

### Information Collected Automatically

**Usage Information:**

* Features you use and when
* Time spent in the app
* Recordings created, shared, and analyzed
* Search queries
* Interactions with other users (likes, comments, follows)
* Performance metrics and scores

**Device Information:**

* Device type and model
* Operating system and version
* Unique device identifiers
* Mobile network information
* IP address
* Browser type (if using web version)
* App version

**Location Information:**

* General location based on IP address
* Precise location (only if you grant permission)

**Audio Recording Metadata:**

* Recording duration
* File size
* Recording quality
* Timestamp and date
* Device used for recording

### Information from Third Parties

**Social Media (if you connect):**

* Public profile information
* Email address
* Profile picture

**Organization Administrators:**

* If you join an Organization, admins may provide your email to invite you

**AI Service Providers:**

* Analysis results and metadata from AI processing

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## 2. How We Use Your Information

We use your information to:

### Provide and Improve the Service

* Create and manage your account
* Process and transcribe your audio recordings
* Analyze your recordings using AI to provide feedback and scores
* Display your content, analytics, and progress
* Enable social features (feed, comments, follows, playlists)
* Provide customer support
* Send service-related notifications

### AI Analysis and Model Improvement

* **Analyze your recordings** using third-party AI models (OpenAI GPT-4, Anthropic Claude, Google Gemini, OpenAI Whisper)
* **Improve our AI models** using anonymized and de-identified data from your recordings
* Train AI to provide better feedback and analysis
* Develop new features and capabilities

**Important:** When we use your data to improve AI models, we remove personally identifiable information. The anonymized data cannot be traced back to you.

### Communications

* Send you account-related emails (verification, password reset)
* Notify you of new features and updates
* Send weekly insights and progress reports
* Respond to your inquiries and requests
* Send marketing communications (you can opt out)

### Analytics and Research

* Understand how users interact with the Service
* Monitor and analyze trends and usage patterns
* Measure the effectiveness of features
* Conduct research to improve the Service

### Security and Fraud Prevention

* Detect and prevent fraud, abuse, and illegal activity
* Protect the security and integrity of the Service
* Enforce our Terms of Service
* Comply with legal obligations

### Organization Features

* Enable team collaboration and analytics
* Provide Organization administrators with member activity and performance data
* Generate team reports and insights

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## 3. How We Share Your Information

We share your information in the following circumstances:

### With Your Consent

* When you share recordings publicly or within an Organization
* When you enable social features (feed posts, comments)
* When you explicitly authorize sharing

### With Service Providers

We share information with third-party service providers who help us operate the Service:

**AI and Machine Learning:**

* **OpenAI** - GPT-4 for analysis, Whisper for transcription
* **Anthropic** - Claude for analysis
* **Google Cloud** - Gemini for analysis, cloud infrastructure

**Infrastructure and Storage:**

* **Google Cloud Platform** - Cloud storage and computing
* **Supabase** - Database, authentication, and real-time features

**Analytics:**

* Usage analytics and monitoring services
* Crash reporting and diagnostics

**Communications:**

* Email service providers
* Push notification services

**Payment Processing:**

* Apple App Store (for iOS subscriptions)
* Google Play Store (for Android subscriptions)

These providers are contractually obligated to protect your information and use it only to provide services to us.

### Within Organizations

If you're part of an Organization:

* Organization administrators can access content you share within the Organization
* Admins can view your usage statistics, performance data, and activity within the Organization
* Team analytics may aggregate your data with other members

### For Legal Reasons

We may disclose your information if required to:

* Comply with laws, regulations, legal processes, or government requests
* Enforce our Terms of Service or other policies
* Protect the rights, property, or safety of Parlay, our users, or the public
* Respond to claims that content violates third-party rights
* Detect, prevent, or address fraud, security, or technical issues

### Business Transfers

If Parlay is involved in a merger, acquisition, sale of assets, or bankruptcy:

* Your information may be transferred to the new owner
* We'll notify you via email or prominent notice before your information is transferred

### Aggregated and De-identified Data

We may share aggregated, de-identified, or anonymized data that cannot identify you:

* For research and analysis
* With business partners
* For marketing and industry reports

**We do NOT sell your personal information.**

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## 4. Your Choices and Controls

### Account Information

* **Update your profile** in app settings
* **Change your email or phone** through account settings
* **Update your password** anytime

### Recording Visibility

* **Control who sees your recordings:**

  * Private (only you)
  * Organization (members only)
  * Public (anyone on Parlay)
* **Delete recordings** anytime
* **Remove recordings from feed** if you change your mind

### Communications

* **Opt out of marketing emails** via unsubscribe link
* **Control push notifications** in device settings or app settings
* **Service-related emails** (account security, important updates) cannot be disabled

### Data Access and Deletion

* **Export your data** by emailing [legal@goparlay.io](mailto:legal@goparlay.io)
* **Delete your account** through app settings or by emailing us
* When you delete your account:

  * We delete your personal information within 30 days
  * Public content you shared may remain if others have interacted with it
  * We may retain some data for legal compliance and fraud prevention
  * Anonymized data used for AI training cannot be removed

### Organization Data

* **Leave an Organization** to stop sharing data with that Organization
* Note: Organization may retain content you shared while a member

### Cookie and Tracking Preferences

* **Adjust cookie settings** in your browser (for web version)
* **Disable advertising ID** in your device settings
* **Limit ad tracking** in iOS or Android settings

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## 5. How We Protect Your Information

We implement security measures to protect your information:

### Technical Safeguards

* **Encryption in transit:** All data transmitted between your device and our servers uses TLS/SSL encryption
* **Encryption at rest:** Audio files and sensitive data are encrypted when stored
* **Secure authentication:** Passwords are hashed using industry-standard algorithms
* **Access controls:** Limited employee access to personal information
* **Secure infrastructure:** Hosted on enterprise-grade cloud providers (Google Cloud)

### Organizational Safeguards

* Employee confidentiality agreements
* Regular security training
* Security audits and assessments
* Incident response procedures
* Data retention policies

### Your Responsibility

You must also protect your information:

* Use a strong, unique password
* Don't share your account credentials
* Secure your device with a passcode/biometric lock
* Log out on shared devices
* Report suspicious activity immediately

### Security Limitations

**No system is 100% secure.** Despite our efforts:

* Data breaches can occur
* Unauthorized access may happen
* We cannot guarantee absolute security

**We are not liable for security breaches beyond our reasonable control.**

If we experience a data breach affecting your information, we'll notify you as required by law.

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## 6. Data Retention

We retain your information as long as necessary to provide the Service and fulfill the purposes described in this Privacy Policy.

### Active Accounts

While your account is active, we retain:

* Account information
* Recordings and content
* Usage data and analytics
* Transaction history

### Deleted Accounts

When you delete your account:

* **Personal information** is deleted within 30 days
* **Recordings and content** are deleted within 30 days
* **Anonymized/aggregated data** may be retained indefinitely for AI improvement and analytics
* **Some information** may be retained longer for:

  * Legal compliance (tax records, transaction history)
  * Fraud prevention and security
  * Resolving disputes
  * Enforcing our Terms of Service

### Backup and Disaster Recovery

* Deleted data may remain in backup systems for up to 90 days
* Backups are automatically deleted after retention period

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## 7. Children's Privacy

**Parlay is not intended for children under 18.**

We do not knowingly collect information from anyone under 18. If we learn we've collected information from a child under 18, we will delete it immediately.

If you believe we've collected information from a child under 18, contact us at [legal@goparlay.io](mailto:legal@goparlay.io).

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## 8. International Users and Data Transfers

### Data Storage Location

Parlay is based in the United States. Your information is:

* Processed and stored primarily in the United States
* May be transferred to and processed in other countries where our service providers operate

**By using Parlay, you consent to the transfer of your information to the United States and other countries, which may have different data protection laws than your jurisdiction.**

### European Economic Area (EEA), UK, and Switzerland

If you're located in the EEA, UK, or Switzerland, you have specific rights under the General Data Protection Regulation (GDPR):

**Legal Basis for Processing:**

* **Contractual necessity:** To provide the Service you've requested
* **Legitimate interests:** To improve the Service, prevent fraud, and ensure security
* **Consent:** For certain uses, such as marketing communications

**Your GDPR Rights:**

* **Right to access:** Request a copy of your personal data
* **Right to rectification:** Correct inaccurate data
* **Right to erasure:** Request deletion of your data ("right to be forgotten")
* **Right to restrict processing:** Limit how we use your data
* **Right to data portability:** Receive your data in a portable format
* **Right to object:** Object to processing based on legitimate interests
* **Right to withdraw consent:** Withdraw consent at any time (doesn't affect prior processing)
* **Right to lodge a complaint:** File a complaint with your local data protection authority

**Data Transfers:**
We transfer data from the EEA to the United States using standard contractual clauses approved by the European Commission.

To exercise your GDPR rights, contact [legal@goparlay.io](mailto:legal@goparlay.io).

### California Residents (CCPA)

If you're a California resident, you have rights under the California Consumer Privacy Act (CCPA):

**Your CCPA Rights:**

* **Right to know:** What personal information we collect, use, and share
* **Right to delete:** Request deletion of your personal information
* **Right to opt-out:** Opt out of "sale" of personal information (we don't sell your data)
* **Right to non-discrimination:** We won't discriminate against you for exercising your rights

**Categories of Information We Collect (CCPA):**

* Identifiers (name, email, phone, IP address)
* Commercial information (subscription history, usage)
* Internet activity (usage data, device info)
* Audio/visual information (recordings, profile pictures)
* Inferences (analysis results, scores, insights)

**Business Purposes for Using Information:**

* Providing and improving the Service
* Communications and customer support
* Security and fraud prevention
* Legal compliance

**Third Parties We Share With:**

* Service providers (AI, infrastructure, analytics)
* Organization administrators (for team accounts)
* Legal authorities (when required)

To exercise your CCPA rights, email [legal@goparlay.io](mailto:legal@goparlay.io) or call **[INSERT BUSINESS PHONE NUMBER]**.

We'll respond within 45 days.

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## 9. Third-Party Services and Links

### Third-Party AI Services

We use third-party AI services to analyze your recordings:

* **OpenAI:** GPT-4 (analysis), Whisper (transcription) - [OpenAI Privacy Policy](https://openai.com/privacy)
* **Anthropic:** Claude (analysis) - [Anthropic Privacy Policy](https://www.anthropic.com/privacy)
* **Google:** Gemini (analysis), Cloud services - [Google Privacy Policy](https://policies.google.com/privacy)

These services have their own privacy policies. We contractually require them to protect your data, but we're not responsible for their practices.

### Other Third-Party Services

Parlay may integrate with or link to third-party services:

* Social media platforms
* Analytics services
* Payment processors (Apple, Google)

We're not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

## Google Calendar Integration

When you connect your Google Calendar to Parlay, we access the following data:
- **Calendar events** (read-only): Event titles, times, descriptions, and video conference URLs
- **Email address**: To identify your account

**How we use this data:**
- Display your upcoming meetings in the Parlay app
- Allow you to select meetings for AI coaching
- Extract video conference URLs (Zoom, Google Meet) to enable our meeting bot to join

**What we do NOT do:**
- We do not modify, delete, or create calendar events
- We do not share your calendar data with third parties
- We do not store calendar event content beyond what's needed for the meeting bot

**Data retention:**
- Calendar connection tokens are stored securely and encrypted
- Meeting metadata is retained only while you have an active account
- You can disconnect your calendar at any time in Settings, which revokes our access

**Revoking access:**
You can disconnect your Google Calendar from Parlay at any time via Settings > Integrations. You can
also revoke access directly from your Google Account at:
https://myaccount.google.com/permissions

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## 10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes:

* We'll update the "Last Updated" date
* We'll notify you via email or in-app notification
* We'll post the updated policy in the app and on our website

**Continued use after changes means you accept the updated Privacy Policy.**

We encourage you to review this Privacy Policy periodically.

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## 11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices:

**All Inquiries:**
Email: [legal@goparlay.io](mailto:legal@goparlay.io)
Website: [https://goparlay.io](https://goparlay.io)

For all matters including:

* General Support
* Legal and Compliance
* Privacy and Data Requests
* GDPR/CCPA Requests
* Data Protection Officer

**Mailing Address:**
**Parlay Technologies LLC**
122 N Independence Way
Saratoga Springs, UT 84045
United States

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## 12. Your Privacy Rights Summary

### All Users

* ✅ Update your account information
* ✅ Control recording visibility
* ✅ Delete your recordings
* ✅ Delete your account
* ✅ Opt out of marketing emails
* ✅ Export your data

### California Residents (CCPA)

* ✅ Right to know what data we collect
* ✅ Right to delete your data
* ✅ Right to opt-out of data sales (we don't sell data)
* ✅ Right to non-discrimination

### EEA/UK/Switzerland Residents (GDPR)

* ✅ Right to access your data
* ✅ Right to rectify inaccurate data
* ✅ Right to erasure ("right to be forgotten")
* ✅ Right to restrict processing
* ✅ Right to data portability
* ✅ Right to object to processing
* ✅ Right to withdraw consent
* ✅ Right to lodge a complaint with authorities

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## Acknowledgment

**By using Parlay, you acknowledge that you have read and understood this Privacy Policy and agree to our collection, use, and sharing of your information as described.**

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**Last Updated:** March 1, 2025

**END OF PRIVACY POLICY**